Common use of TERMS OF SETTLEMENT Clause in Contracts

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three years following the Effective Date. 2. Respondent shall pay civil penalties to the United States Treasury in the amount of five thousand, two hundred and four dollars ($5,204). 3. Respondent shall provide IER with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties no later than close of business on the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) business days of receiving fund transfer instructions from IER. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. ▇▇▇-▇▇-▇▇▇, in the subject line. 4. Within 15 days from the Effective Date, Respondent shall send a W-4 to the Charging Party per IRS requirements with a prepared return envelope. The Charging Party will send the completed W-4 to Respondent for processing. Upon receipt of the W-4, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment to the Charging Party in the amount of $13,920 plus interest, less any withholding required by law, which constitutes back pay plus accumulated interest calculated at the IRS underpayment rate, compounded daily, through the Effective Date. IER will provide Respondent with payment instructions no later than five days from the Effective Date. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, and attach an image of the check. 5. Within 45 days after remitting the Charging Party’s W-2 form for calendar year 2021 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the payment made to the Charging Party in paragraph 4 to the appropriate period. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentation. 6. In accordance with 8 U.S.C. § 1324b, Respondent shall not: (a) Discriminate on the basis of citizenship, immigration status or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate in the employment eligibility verification and reverification process. Respondent shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidate, threaten, coerce, or retaliate against any person for their participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 7. Respondent shall comply with the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national origin, and shall not prohibit employees from working because they received a Tentative NonConfirmation result in E-Verify. 8. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with IER. 9. Respondent shall post an English and Spanish version of the IER “If You Have

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually dually-signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three two years following the Effective Date. 2. Respondent shall pay civil penalties to the United States Treasury in the amount of five four thousand, two hundred and four fifty dollars ($5,2044,250). 3. Respondent shall provide IER with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties no later than close of business on the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) business days of receiving fund transfer instructions from IER. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. # ▇▇▇-▇▇-▇▇▇, in the subject line. 4. Within 15 days from the Effective Date, Respondent shall send a W-4 to the Charging Party per IRS requirements with a prepared return envelope. The Charging Party will send the completed W-4 to Respondent for processing. Upon receipt of the W-4, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment check to the Charging Party in the amount of $13,920 plus interest7,641.05, less any withholding required by law, which constitutes back pay plus accumulated interest calculated at the IRS underpayment rate, compounded daily, through the Effective Date. IER will provide Respondent with payment instructions a mailing address for the Charging Party no later than five days from the Effective Date. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, made and attach an image of the check. 5. Within 45 days after remitting the Charging Party’s W-2 form for calendar year 2021 2020 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the payment made to the Charging Party in paragraph 4 to the appropriate periodperiods. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentation. 6. In accordance with 8 U.S.C. § 1324b▇▇▇▇▇, Respondent ▇▇▇▇▇▇▇▇▇▇ shall not: (a) Discriminate discriminate on the basis of citizenship, immigration status or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate discriminate in the employment eligibility verification and reverification process. ; Respondent shall shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidateintimidate, threaten, coerce, or retaliate against any person for their his or her participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 7. Respondent shall comply with the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national originstatus, and shall not prohibit employees from working because they received a Tentative NonConfirmation Non- Confirmation result in E-Verify. 8. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with IER. 9. Respondent shall post an English and Spanish version of the IER “If You Have

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually dually- signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and Agreement shall be three two years following the Effective Date. 2. Respondent shall pay a civil penalties penalty to the United States Treasury in the amount of five thousand, two hundred and four dollars ($5,204)7,488.00. 3. Respondent shall provide IER with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties no later than close of business on the Effective Date. Respondent shall pay the The monies discussed in paragraph 2 shall be paid via the FedWire electronic fund transfer system within ten (10) 10 business days of receiving Respondent’s receipt of a fully signed copy of this Agreement and fund transfer instructions. ▇▇▇ will provide Respondent instructions from IERfor the FedWire electronic transfer. On the day of payment, Respondent shall send a confirmation of the payment to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇on the day the funds are transferred. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. ▇▇▇DJ# 197-▇▇-▇▇▇12C-1726, in the subject line. 4. Within 15 days from the Effective Date, Respondent shall send a W-4 to pay the Charging Party per IRS requirements with a prepared return envelope. The Charging Party will send the completed W-4 to Respondent for processing. Upon receipt of the W-4$1,750 in back pay, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment to the Charging Party in the amount of $13,920 plus interest, less any withholding required by law, which constitutes back pay plus accumulated interest calculated at the IRS underpayment rate, compounded daily, daily through the Effective Date, less any withholding required by law. IER will provide Respondent with payment instructions no later than five Within three business days from of the Effective Date, ▇▇▇ will notify Respondent of the total back pay figure with interest included. Respondent shall deduct any taxes and other required withholdings from the amount due to the Charging Party. Within 30 calendar days of IER’s notice, Respondent shall make the payment to the Charging Party using the method of payment the Charging Party selects. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, made and attach an image of the checkcheck or evidence of the other method of payment the Charging Party selected. 5. Within 45 calendar days after remitting the Charging Party’s W-2 form for calendar year 2021 2024 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the payment made to the Charging Party in paragraph 4 to the appropriate periodperiods in 2022. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentation. 6. In accordance compliance with 8 U.S.C. § 1324b, Respondent shall not: (a) Discriminate a. discriminate on the basis of citizenship, immigration status or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate b. discriminate in the employment eligibility verification and reverification process. ; accordingly, Respondent shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidatec. intimidate, threaten, coerce, or retaliate against any person for their his or her participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 7. Respondent shall comply with the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national origin, and shall not prohibit employees from working because they received a Tentative NonConfirmation result in E-Verify. 8. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with IER. 9. Respondent shall post an English and Spanish version of the IER IER’s “If You HaveHave The Right to Work” poster (“IER Poster”), in color and measuring no smaller than 8.5” by 11”, an image of which is available at ▇▇▇▇▇://▇▇▇.▇▇▇▇▇▇▇.▇▇▇/crt/worker-information#poster, at Respondent’s Gardena, California location in all places where notices to employees and job applicants are normally posted. The IER Poster will be posted within 14 calendar days from the Effective Date and will remain posted for the term of the Agreement. 8. Respondent shall review, and if necessary, create or revise any existing employment policies, training materials, and guidance that relate to hiring, onboarding, or the employment eligibility verification (“EEV”) process, to comply with the requirements in Paragraph 8(a)-(h). Within 60 calendar days of the Effective Date of this Agreement, Respondent shall submit such materials to IER for review and approval; IER’s review is limited to ensuring that such materials comply with 8 U.S.C. § 1324b and this Agreement. Respondent will implement, and distribute as appropriate, the policies, training materials, and guidance within 30 calendar days of IER’s approval. During the term of this Agreement, Respondent shall provide any revisions to such policies, training materials, and guidance to IER for approval at least 30 calendar days prior to the proposed effective date of such revisions. Respondent’s EEV policies, training materials, and guidance shall meet the following requirements: a. Mandate compliance with all appliable Form I-9 and E-Verify rules; b. Prohibit requesting more or different documents than required by law to establish permission to work in the United States, requesting specific EEV documents, or rejecting valid EEV documents, because of an individual’s citizenship, immigration status, or national origin, regardless of whether such actions occur in the hiring, onboarding, or EEV processes; c. Include citizenship status and immigration status as prohibited bases of discrimination—unless required to comply with a law, regulation, executive order, government contract, or Attorney General directive pursuant to 8 U.S.C.§ 1324b(a)—as well as national origin. Such prohibitions shall also be included in any Equal Employment Opportunity statements Respondent provides in printed or electronic materials available to the public or employees; d. Set forth how to handle name discrepancies in Form I-9 documentation including: (1) that if an employee presents a document(s) with a different name than the name entered in Section 1, Respondent’s representative reviewing the document(s) will accept the document(s), provided the representative determines the document reasonably appears to be genuine and to relate to the employee, (2) if Respondent’s representative determines such document(s) does not reasonably appear to be genuine or to relate to the employee, the representative will ask the employee to present other document(s) from the Form I-9 List of Acceptable Documents, and (3) Respondent’s representatives will examine an employee’s Form I-9 document(s) with the same level of scrutiny regardless of the employee’s citizenship status; e. Explain the reverification process, including the types of documents an employee may present for reverification (any document from either List A or List C), and prohibit unnecessary reverification of employees for the Form I- 9, including prohibiting reverification of individuals who attested on the Form I-9 to being a lawful permanent resident and presented a Permanent Resident Card at initial hire, and individuals who attested on the Form I-9 to being a noncitizen authorized to work, did not include an expiration date in section 1 of the Form I-9, and presented documents that do not require reverification; f. Include copies of or links to the most current version of the Form I-9, ▇▇▇.▇▇▇▇▇.▇▇▇/▇-▇, the USCIS Employment Eligibility Verification Handbook for Employers (M-274) (“Handbook”), available at ▇▇▇▇▇://▇▇▇.▇▇▇▇▇.▇▇▇/i-9-central/form-i-9-resources/handbook-for- employers-m-274, and the most current USCIS E-Verify Manual (M-775) (“Manual”), available at ▇▇▇▇▇://▇▇▇.▇-▇▇▇▇▇▇.▇▇▇/e-verify-user-manual. g. Refer applicants and employees who make a complaint of discrimination based on national origin, citizenship, or immigration status in connection with hiring, firing, recruiting or referring for a fee, or Form I-9 employment eligibility verification and/or reverification promptly to IER by directing the affected individual to the IER Posters, IER’s worker hotline (800-255-7688), and IER’s website (▇▇▇.▇▇▇▇▇▇▇.▇▇▇/▇▇▇), and advise the affected individual of the right to file a charge of discrimination with IER; and h. Provide that Respondent shall not intimidate or take any retaliatory action against any individual for opposing any employment practice made unlawful by 8 U.S.C. § 1324b or which the individual reasonably believes to be unlawful under 8 U.S.C. § 1324b, for filing a charge, or for participating in any investigation or action under 8 U.S.C. § 1324b. 9. Within 30 calendar days of the Effective Date, Respondent shall ensure that any software or other electronic program it uses for EEV purposes is not tracking or prompting for reverification any employees or documents that do not require reverification, including Permanent Resident Cards. 10. Within 90 calendar days of the Effective Date, Respondent shall ensure that all individuals who are responsible for formulating, providing training on, or implementing Respondent’s hiring, firing, equal employment, and employment eligibility verification policies, and all individuals at Respondent’s Gardena, California location whose job duties involve any part of the EEV process (“Covered Personnel”), receive training on their obligations under 8 U.S.C. § 1324b, as follows: a. The training will consist of participating in an IER-provided free webinar presentation, which will be provided on one or more mutually agreed upon dates, or attending IER’s on-demand webinar available at ▇▇▇▇▇://▇▇▇.▇▇▇▇▇▇▇.▇▇▇/crt/video/employer-training-avoiding-unlawful- immigration-related-employment-discrimination; b. All employees will be paid their normal rate of pay, and the training will occur during their normally scheduled workdays and work hours. Respondent shall be responsible for all payroll costs and employee wages associated with these training sessions; c. During the term of the Agreement, all Covered Personnel who assume or resume their duties after the initial training period described in this paragraph has been conducted, shall participate in an online IER Employer/HR webinar, or view the on-demand webinar, within 14 calendar days of assuming or resuming their duties; and d. Respondent shall compile attendance records listing the individuals who attend the training(s) described in this paragraph, including their full name, job title, signature, and the date(s) of the training, and shall send the records via email to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ (or any other individual IER designates in writing) within 14 calendar days of each training session. The emails transmitting attendance records shall have the reference number DJ # 197-12C-1726 in the subject line. 11. During the term of this Agreement, ▇▇▇ reserves the right to make such reasonable inquiries as it, in its discretion, believes necessary or appropriate to assess Respondent’s compliance with this Agreement, including but not limited to, requiring written reports from Respondent concerning its compliance; inspecting Respondent’s premises; interviewing Respondent’s employees, officials or other persons; and requesting copies of Respondent’s documents. 12. If ▇▇▇ has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may exercise its discretion to notify Respondent in writing of the purported violation rather than initiate a new investigation or seek immediate judicial enforcement of the Agreement. Respondent will then be given 30 calendar days from the date ▇▇▇ notifies it in which to cure the violation(s) to ▇▇▇’s satisfaction before ▇▇▇ deems Respondent to be in violation of this Agreement and proceeds to take enforcement actions. 13. Nothing in this Agreement limits ▇▇▇’s right to inspect Respondent’s Forms I-9 and attachments within three business days pursuant to 8 C.F.R. § 274a.2(b)(2)(ii) and 28 C.F.R. § 44.302(b). 14. This Agreement does not affect the right of any individual to file an IER charge alleging an unfair immigration-related employment practice against Respondent, ▇▇▇’s authority to investigate such charge or file a complaint on behalf of any such individual, or IER’s authority to conduct an independent investigation of Respondent’s employment practices occurring after the Effective Date or outside the scope of the IER Investigation. 16. This Agreement resolves any and all differences under 8 U.S.C. § 1324b between ▇▇▇ and Respondent relating to or encompassed by the IER Investigation through the Effective Date. The provisions of paragraphs 2 and 4 notwithstanding, IER shall not seek from Respondent any additional civil penalty or payments for or relating to the alleged violations of 8 U.S.C. § 1324b, or any other allegations encompassed by or relating to the IER Investigation through the Effective Date.

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually dually-signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three two years following the Effective Date. 2. Respondent shall pay civil penalties to the United States Treasury in the amount of five thousand$4,144, two hundred and four dollars ($5,204)in accordance with the process described in paragraph 3. 3. Respondent shall provide IER ▇▇▇ with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties no later than close of three business on days from the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) 10 business days of receiving fund transfer instructions from IER▇▇▇. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. # ▇▇▇-▇▇-▇▇▇, in the subject line. 4. Within 15 days from the Effective Date, Respondent shall send a W-4 to pay the Charging Party per IRS requirements with a prepared return envelope. The Charging Party will send the completed W-4 to Respondent for processing. Upon receipt of the W-4back pay, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment to the Charging Party in the amount of $13,920 plus interest85,000, less any withholding withholdings required by law, which constitutes back pay plus accumulated interest calculated at . Respondent shall make the IRS underpayment rate, compounded daily, through payment within 30 days of the Effective Date. IER will provide Respondent with payment instructions no later than five days shall obtain any necessary tax paperwork from the Effective DateCharging Party in advance of the deadline for sending the back pay and shall deduct any taxes and other required withholdings from the amount due to the Charging Party. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, made and attach an image of the checkcheck or evidence of the other method of payment the Charging Party selected. 5. Within 45 days after remitting the Charging Party’s W-2 form for calendar year 2021 2023 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the payment made to the Charging Party in paragraph 4 to the appropriate periodperiods. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentation. 6. In accordance with 8 U.S.C. § 1324b, Respondent shall not: (a) Discriminate on the basis of citizenship, immigration status or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate in the employment eligibility verification and reverification process. Respondent shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidate, threaten, coerce, or retaliate against any person for their participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 7. Respondent shall comply with the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national origin, and shall not prohibit employees from working because they received a Tentative NonConfirmation result in E-Verify. 8. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with ▇▇▇, the IER Investigation, or this Agreement except as required by law, court order, or other legal process. 7. This Agreement resolves any and all differences under 8 U.S.C. § 1324b between the Parties relating to the Investigation, DJ # ▇▇▇-▇▇-▇▇, including all matters and allegations described in IER’s August 1, 2022 reasonable cause determination through the Effective Date. The provisions of paragraph 2 notwithstanding, IER shall not seek from Respondent any additional civil penalty or other relief for the citizenship status discrimination and retaliation in violation of 8 U.S.C. § 1324b that is the subject of the IER Investigation (DJ # 197-22-60) through the Effective Date. 8. In accordance with 8 U.S.C. § 1324b, Respondent shall not discriminate in hiring or recruitment on the basis of citizenship status. In addition, Respondent shall: (a) Beginning no later than 30 days from the Effective Date, when advertising PERM-related positions, not include a statement or any indication that the position is related to a PERM application, to ensure that advertisements for PERM-related positions shall appear indistinguishable from advertisements for non-PERM related positions; (b) Beginning no later than 90 days from the Effective Date, not require applications for PERM jobs to be submitted in a manner different from the process used for non-PERM jobs; (c) Beginning no later than 90 days from the Effective Date, enter into Respondent’s recruiting system all applicants to all PERM-related positions who apply via Respondent’s careers website, ▇▇▇▇▇://▇▇▇▇▇▇.▇▇▇▇▇▇▇▇▇.▇▇/▇▇▇▇▇▇▇, enabling such applicants to be searchable and remain searchable for all positions in the same manner as applicants to non-PERM related positions at Respondent; and (d) Not intimidate, threaten, coerce, or retaliate against any person for his or her participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 9. Respondent shall continue to post an English and Spanish version of the IER “If You HaveHave The Right to Work” poster (“IER Poster”), in color and measuring no smaller than 8.5” x 11”, an image of which is available at ▇▇▇▇▇://▇▇▇.▇▇▇▇▇▇▇.▇▇▇/crt/worker-information#poster, in all places where notices to employees and job applicants are normally posted. 10. Within 30 days of the Effective Date, Respondent shall issue a written statement (a copy of which is appended as Attachment A) to recruiters who recruit for U.S.- based positions for Respondent about their obligations under 8 U.S.C. § 1324b and this Agreement. During the term of the Agreement, before beginning recruitment in connection with a PERM application, Respondent will provide the hiring manager(s) for the PERM-related position with a copy of this written statement, unless the hiring manager(s) has already received the statement. 11. Within 90 days of the Effective Date, Respondent shall review any existing employment policies and revise such policies, or develop new policies, to ensure that such policies: (a) Prohibit discrimination on the basis of citizenship status, and national origin in the hiring and firing process; (b) Include citizenship status (which includes protected immigration status) and national origin as prohibited bases of discrimination; any similar Equal Employment Opportunity (EEO) statements Respondent includes in printed or electronic materials available to the public or employees shall also include these prohibited bases of discrimination; (c) Promptly address and, if appropriate, remedy any allegation of citizenship-status discrimination in employment; and (d) Prohibit intimidation or retaliation as defined and required by 8 U.S.C. § 1324b(a)(5). 12. During the term of this Agreement, Respondent shall provide any proposed revisions to Attachment A, or to the employment policies referenced in paragraph 11, to IER for approval at least 30 days prior to the proposed effective date of such new or revised policies. 13. Beginning 180 days after the Effective Date and continuing every six months thereafter within the term of the Agreement, Respondent shall provide IER with the recruitment reports, as described by 20 C.F.R. § 656.17(g), prepared during the prior six-month review period for each of Respondent’s PERM-related positions during the period. 14. Respondent shall provide all North American talent acquisition recruiting personnel with training on their obligation to comply with 8 U.S.C. § 1324b, as follows: (a) Within 90 days of the Effective Date, all North American talent acquisition recruiting personnel shall complete a training pursuant to paragraph 14(b) of this Agreement. (b) The trainings in this paragraph will consist of a live IER-provided free webinar presentation at times mutually agreed upon by the Parties, and/or a recorded training that ▇▇▇ has approved. (c) During the term of the Agreement, all North American talent acquisition recruiting personnel who are hired or take on these responsibilities after the training described in paragraph 14(a) has been conducted, shall attend a training as described in paragraph 14(b) within 60 days of hire or promotion. During the term of the Agreement, before any candidates are submitted to the hiring manager in connection with a PERM application, the relevant hiring manager shall complete the training described in paragraph 14(b), unless they have already completed such training. (d) Respondent will pay all employees their normal rate of pay during the training, and the training will occur during their normally scheduled workdays and work hours. Respondent shall bear all of its own costs associated with these training sessions. (e) Respondent shall compile attendance records listing the individuals who attend the trainings described in this paragraph, including the individual(s)’s full name, job title, office location, and the date of the training, and send any attendance records via email to ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ (or any other individual IER designates) each quarter during the term of the Agreement. 15. If ▇▇▇ has reason to believe that Respondent is in violation of any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new investigation or seek to judicially enforce the Agreement. Respondent will then have 45 days from the date of IER’s notification to provide IER with a response to the alleged violation. If Respondent makes a good faith response that is not satisfactory to IER but may become satisfactory with additional time to cure the alleged violation, IER will provide Respondent a cure period of 30 days. If ▇▇▇ is not satisfied with Respondent’s efforts to cure, ▇▇▇ may then deem Respondent to be in violation of this Agreement. ▇▇▇ also reserves the right to make such reasonable inquiries as it, in its discretion, believes necessary or appropriate to assess Respondent’s compliance with this Agreement. 16. This Agreement does not affect the right of any individual to file a charge under the Act alleging an unfair immigration-related employment practice against Respondent, ▇▇▇’s authority to investigate Respondent or file a complaint on behalf of any such individual, or IER’s authority to conduct an independent investigation of Respondent’s employment practices occurring after the Effective Date or outside of the scope of the Investigation.

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually dually-signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three two years following the Effective Date. 2. Respondent shall pay civil penalties to the United States Treasury in the amount of five thousand, two one thousand four hundred and four dollars ($5,2041,400). 3. Respondent shall provide IER ▇▇▇ with the name, title, email address, and telephone number of the individual responsible for effectuating the payment of the civil penalties referenced in paragraph 2 no later than close of business on seven days after the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) business 14 days of receiving fund transfer instructions from IER▇▇▇. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. ▇▇▇# 197-▇▇-▇▇▇11E-383, in the subject line. 4. Within Respondent shall, within 15 days from the Effective Date, Respondent shall send the Charging Party, by email and certified mail, a W-4 to form permitting the Charging Party per to elect a method of payment for the payment referenced in paragraph 5 and an IRS requirements with a prepared return envelopeForm W-4 for the purpose of allowing him to change his withholdings. 5. The Respondent shall pay the Charging Party will send the completed W-4 to Respondent for processing. Upon Party, within 15 days from its receipt of the W-4Charging Party’s payment election form referenced in paragraph 4, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment to the Charging Party in the amount of $13,920 plus interest13,045, less any withholding required by law, which constitutes back pay plus accumulated interest calculated at applicable interest. Respondent shall pay the IRS underpayment rate, compounded daily, through Charging Party using the Effective Date. IER will provide Respondent with method of payment instructions no later than five days from selected in the Effective DateCharging Party’s payment election form. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, made and attach an image of the check. 56. Within 45 days after remitting the Charging Party’s W-2 form for calendar year 2021 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the payment made to the Charging Party in paragraph 4 5 to the appropriate periodperiods. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentation. 67. In accordance with 8 U.S.C. § 1324b, Respondent shall not: (a) Discriminate discriminate on the basis of citizenship, immigration status or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate discriminate in the employment eligibility verification and reverification process. process in violation of 8 U.S.C. § 1324b; Respondent shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidateintimidate, threaten, coerce, or retaliate against any person for their his or her participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 78. Respondent shall comply with the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national origin, and shall not prohibit employees from working because they received a Tentative NonConfirmation Nonconfirmation result in E-Verify. 89. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with IER▇▇▇. 910. Respondent shall post an English and Spanish version of the IER “If You HaveHave The Right to Work” poster (“IER Poster”), in color and measuring no smaller than 8.5” x 11”, an image of which is available at ▇▇▇▇▇://▇▇▇.▇▇▇▇▇▇▇.▇▇▇/crt/worker- information#poster, in all places where notices to employees and job applicants are normally posted. Respondent shall post the IER Poster within 14 days from the Effective Date of this Agreement and it will remain posted for two years thereafter.

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually dually-signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three two years following the Effective Date. 2. Respondent shall pay civil penalties to the United States Treasury in the amount of five four thousand, two hundred and four fifty dollars ($5,2044,250). 3. Respondent shall provide IER ▇▇▇ with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties no later than close of business on the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) business days of receiving fund transfer instructions from IER▇▇▇. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. # ▇▇▇-▇▇-▇▇▇, in the subject line. 4. Within 15 days from the Effective Date, Respondent shall send a W-4 to the Charging Party per IRS requirements with a prepared return envelope. The Charging Party will send the completed W-4 to Respondent for processing. Upon receipt of the W-4, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment check to the Charging Party in the amount of $13,920 plus interest7,641.05, less any withholding required by law, which constitutes back pay plus accumulated interest calculated at the IRS underpayment rate, compounded daily, through the Effective Date. IER ▇▇▇ will provide Respondent with payment instructions a mailing address for the Charging Party no later than five days from the Effective Date. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, made and attach an image of the check. 5. Within 45 days after remitting the Charging Party’s W-2 form for calendar year 2021 2020 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the payment made to the Charging Party in paragraph 4 to the appropriate periodperiods. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇ at ▇▇▇▇▇.▇.▇▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentation. 6. In accordance with 8 U.S.C. § 1324b, Respondent shall not: (a) Discriminate discriminate on the basis of citizenship, immigration status or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate discriminate in the employment eligibility verification and reverification process. ; Respondent shall shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidateintimidate, threaten, coerce, or retaliate against any person for their his or her participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 7. Respondent shall comply with the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national originstatus, and shall not prohibit employees from working because they received a Tentative NonConfirmation Non- Confirmation result in E-Verify. 8. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with IER▇▇▇. 9. Respondent shall post an English and Spanish version of the IER “If You Have

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually dually-signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three years following the Effective Date. 2. Respondent shall pay a civil penalties penalty to the United States Treasury in the amount of five thousand, two one thousand nine hundred and four twenty eight dollars ($5,2041,928). 3. Respondent shall provide IER with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties described in paragraph 2 above no later than close of business on seven days from the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) business 14 days of receiving fund transfer instructions from IER. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇ ▇▇ . ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. # ▇▇▇-▇▇-▇▇▇, in the subject line. 4. Within Respondent shall, within 15 days from the Effective Date, Respondent shall send the Charging Party, by email and certified mail, a W-4 to form permitting the Charging Party per to elect a method of payment for the payment referenced in paragraph 5 and an IRS requirements with a prepared return envelopeForm W-4 for the purpose of allowing him to change his withholdings. 5. The Respondent shall pay the Charging Party will send the completed W-4 to Respondent for processing. Upon Party, within 15 days from its receipt of the W-4Charging Party’s payment election form referenced in paragraph 4, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment to the Charging Party in the amount of $13,920 plus interest1,789.32, less any withholding required by law, which constitutes back pay plus accumulated interest calculated at applicable interest. Respondent shall pay the IRS underpayment rate, compounded daily, through Charging Party using the Effective Date. IER will provide Respondent with method of payment instructions no later than five days from selected in the Effective DateCharging Party’s payment election form. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇ ▇▇ . ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, made and attach an image of the check. 5. Within 45 days after remitting the Charging Party’s W-2 form for calendar year 2021 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the check or proof that payment was made to the Charging Party in paragraph 4 to the appropriate period. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentationby direct deposit. 6. In accordance with 8 U.S.C. § 1324b, Respondent shall not: (a) Discriminate discriminate on the basis of citizenship, immigration status or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate discriminate in the employment eligibility verification and reverification process. process in violation of 8 U.S.C. § 1324b; Respondent shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidateintimidate, threaten, coerce, or retaliate against any person for their participation participating in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 7. Respondent shall comply with the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national origin, and shall not prohibit employees from working because they received a Tentative NonConfirmation Nonconfirmation result in E-Verify. 8. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with IER. 9. Respondent shall post an English and Spanish version shall, within 15 days from the Effective Date, remove all reference to to the termination of the IER “If You HaveCharging Party, and within 3 days therafter notify him in writing that this has been done. Respondent shall send a copy of the correspondence to the Charging Party to ▇▇▇▇▇ ▇. ▇▇▇▇▇ at ▇▇▇▇▇.▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇.

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three years following the Effective Date. 2. Respondent shall pay civil penalties to the United States Treasury in the amount of five thousand, two hundred and four dollars ($5,204). 3. Respondent shall provide IER ▇▇▇ with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties no later than close of business on the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) business days of receiving fund transfer instructions from IER▇▇▇. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. ▇▇▇-▇▇-▇▇▇, in the subject line. 4. Within 15 days from the Effective Date, Respondent shall send a W-4 to the Charging Party per IRS requirements with a prepared return envelope. The Charging Party will send the completed W-4 to Respondent for processing. Upon receipt of the W-4, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment to the Charging Party in the amount of $13,920 plus interest, less any withholding required by law, which constitutes back pay plus accumulated interest calculated at the IRS underpayment rate, compounded daily, through the Effective Date. IER ▇▇▇ will provide Respondent with payment instructions no later than five days from the Effective Date. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, and attach an image of the check. 5. Within 45 days after remitting the Charging Party’s W-2 form for calendar year 2021 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the payment made to the Charging Party in paragraph 4 to the appropriate period. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentation. 6. In accordance with 8 U.S.C. § 1324b, Respondent shall not: (a) Discriminate on the basis of citizenship, immigration status or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate in the employment eligibility verification and reverification process. Respondent shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidate, threaten, coerce, or retaliate against any person for their participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 7. Respondent shall comply with the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national origin, and shall not prohibit employees from working because they received a Tentative NonConfirmation result in E-Verify. 8. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with IER▇▇▇. 9. Respondent shall post an English and Spanish version of the IER “If You Have

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually dually-signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three years following the Effective Date. 2. Respondent shall pay civil penalties to the United States Treasury in the amount of five thousand$4,465, two hundred and four dollars ($5,204)in accordance with the process described in paragraph 3. 3. Respondent shall provide IER ▇▇▇ with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties penalty no later than close of three business on days from the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) 10 business days of receiving fund transfer instructions from IER▇▇▇. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. # ▇▇▇-▇▇-▇▇▇, in the subject line. 4. Within 15 days from the Effective Date, Respondent shall send a W-4 to pay the Charging Party per IRS requirements with a prepared return envelope. The Charging Party will send $3,360 in back pay, plus interest on the completed W-4 to Respondent for processing. Upon receipt of the W-4, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment to the Charging Party in the amount of $13,920 plus interest, less any withholding required by law, which constitutes back pay plus accumulated interest 3,360 figure calculated at the IRS underpayment rate, compounded daily, daily through the Effective Date, less any withholding required by law. IER will provide Respondent with payment instructions no later than five Within three business days from of the Effective Date, ▇▇▇ will notify Respondent of the total back pay figure with interest included. Respondent shall deduct any taxes and other required withholdings from the amount due to the Charging Party. Within 30 business days of ▇▇▇’s notice, Respondent shall make the payment to the Charging Party using the method of payment the Charging Party selects. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that payment was made, made and attach an image of the checkcheck or evidence of the other method of payment the Charging Party selected. 5. Within 45 business days after remitting the Charging Party’s W-2 form for calendar year 2021 2023 to the Social Security Administration under IRS regulations, and pursuant to the provisions of IRS Publication 957, Respondent shall file a special report to the Social Security Administration allocating the payment made to the Charging Party in paragraph 4 to the appropriate periodperiods in 2022. On the day Respondent submits the documentation, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentation. 6. In accordance with This Agreement resolves any and all differences under 8 U.S.C. § 1324b1324b between the parties relating to the Investigation, DJ # ▇▇▇-▇▇-▇▇▇, through the Effective Date. The provisions of paragraph 2 notwithstanding, IER shall not seek from Respondent any additional civil penalty for the citizenship status discrimination in violation of 8 U.S.C. § 1324b that is the subject of the Investigation (DJ # 197-35- 531) through the Effective Date. 7. Respondent shall not: (a) a. Discriminate on the basis of citizenshipcitizenship status, immigration status status, or national origin in violation of 8 U.S.C. § 1324b., including not discriminating in recruiting, referring job applicants, hiring, or firing on the basis of citizenship status or immigration status except as required to comply with a law, regulation, executive order, government contract, or Attorney General directive; or (b) Discriminate in the employment eligibility verification and reverification process. Respondent shall (i) honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) b. Intimidate, threaten, coerce, or retaliate against any person for their his or her participation in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 78. Within 14 calendar days of the Effective Date, Respondent shall transmit via e- mail to all employees, agents, and contractors with any role in recruiting or hiring (collectively, “Hiring Personnel”) the IER fact sheet “Information for Employers About Citizenship Status Discrimination” available at ▇▇▇▇▇://▇▇▇.▇▇▇▇▇▇▇.▇▇▇/crt/page/file/1080256/download, and the fact sheet “Unlawful Employment Discrimination Based on Citizenship and National Origin” available at ▇▇▇▇▇://▇▇▇.▇▇▇▇▇▇▇.▇▇▇/crt/page/file/1132631/download. Respondent shall comply with will require each of the E-Verify rules and responsibilities set forth under its Memorandum Hiring Personnel to acknowledge in writing their review of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national originIER materials within five calendar days of receipt, and shall not prohibit employees from working because they received a Tentative NonConfirmation result in E-Verify. 8. Respondent shall not disclose to any employer or prospective employer shall, upon IER’s request, provide copies of the Charging Party any information or documentation related written acknowledgments to the Charging Party’s charge filed with IER. 9. Within 60 calendar days of the Effective Date, Respondent shall post create (or revise), and provide to IER for review and approval, employment policies that: a. Prohibit discrimination on the basis of citizenship or immigration status, and national origin in the recruiting, hiring, and firing process, in accordance with 8 U.S.C. § 1324b; b. Prohibit asking questions during the recruiting or hiring process related to an English applicant’s specific citizenship or immigration status unless a specific citizenship or immigration status is required for the position by law, regulation, executive order, government contract, or Attorney General directive; c. Include citizenship, immigration status, and Spanish national origin as prohibited bases of discrimination in any Equal Employment Opportunity (EEO) statements Respondent provides in printed or electronic materials available to the public or employees; d. Refer applicants and employees who complain, formally or informally, of discrimination in the hiring, firing, or Form I-9 employment eligibility verification and reverification process immediately to IER by promptly directing the affected individual to the IER Poster and ▇▇▇’s worker hotline (800-255-7688) and website (▇▇▇.▇▇▇▇▇▇▇.▇▇▇/▇▇▇), and advise the affected individual of his or her right to file a charge of discrimination with IER; and e. Prohibit any reprisal action against an employee or prospective employee for having opposed any employment practice made unlawful by 8 U.S.C. § 1324b, for exercising any right or privilege secured by 8 U.S.C. § 1324b, or for filing any charge, or participating in a lawful manner in any investigation or action under 8 U.S.C. § 1324b. Within 10 calendar days of ▇▇▇’s review and approval, Respondent shall implement the revised employment policies and share them with all employees. 10. During the term of this Agreement, Respondent shall provide any proposed revisions to the employment policies referenced in paragraph 9 to IER for approval at least 30 calendar days prior to the proposed effective date of such new or revised policies. 11. Respondent shall provide all Hiring Personnel with training on their obligation to comply with 8 U.S.C. § 1324b, as follows: (a) Within 90 calendar days of the Effective Date, all Hiring Personnel shall complete an IER-approved webinar training. (b) During the term of the Agreement, all Hiring Personnel who are hired or take on these responsibilities after Respondent complies with the training obligations in 11(a), shall view a recorded version of the training within 60 calendar days of hire or promotion. (c) Respondent will pay all employees their normal rate of pay during the training, and the training will occur during their normally scheduled workdays and work hours. Respondent shall bear all of its own costs associated with these training sessions. (d) Respondent shall compile attendance records listing the individuals who attend the trainings described in this paragraph, including the individual(s)’s full name, job title, office location, signature, and the date of the training, and make such records available to IER “upon request. 12. During the term of this Agreement, IER reserves the right to make such reasonable inquiries as it, in its discretion, believes necessary or appropriate to assess Respondent’s compliance with this Agreement, including but not limited to, requiring written reports from Respondent concerning its compliance; inspecting Respondent’s premises; interviewing Respondent’s employees, officials or other persons; and requesting relevant non-privileged documents related to such compliance. 13. Nothing in this Agreement limits ▇▇▇’s right to inspect Respondent’s Forms I-9 within three business days pursuant to 8 C.F.R. § 274a.2(b)(2)ii. Respondent shall, at IER’s discretion, provide data fields from such documents in Excel spreadsheet format unless requested otherwise. 14. If You Have▇▇▇ has reason to believe that Respondent is in violation of any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new investigation or seek to judicially enforce the Agreement. If ▇▇▇ has exercised its discretion to notify Respondent of the purported violation, Respondent shall have 30 calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction. 15. This Agreement does not affect the right of any individual to file a charge under the Act alleging an unfair immigration-related employment practice against Respondent, ▇▇▇’s authority to investigate Respondent or file a complaint on behalf of any such individual, or IER’s authority to conduct an independent investigation of Respondent’s employment practices occurring after the Effective Date or outside of the scope of the Investigation.

TERMS OF SETTLEMENT. 1. This Agreement becomes effective as of the date of the latest signature on the dually dually-signed Agreement, which date is considered to be and referenced herein as the “Effective Date.” The “term of this Agreement” is defined as and shall be three years following the Effective Date. 2. Respondent shall pay civil penalties to the United States Treasury in the amount of five thousand, two hundred and four dollars ($5,204)2,232.00. 3. Respondent shall provide IER ▇▇▇ with the name, title, email address, and telephone number of the individual responsible for effectuating payment of the civil penalties no later than close of business on the Effective Date. Respondent shall pay the monies discussed in paragraph 2 via the FedWire electronic fund transfer system within ten (10) business days of receiving fund transfer instructions from IER▇▇▇. On the day of payment, Respondent shall send confirmation of the payment to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. The email confirming payment shall have Respondent’s name and the investigation number, DJ No. # ▇▇▇-▇▇-▇▇▇, in the subject line. 4. Within 15 days from the Effective Date, Respondent shall send a W-4 to the pay Charging Party per IRS requirements with a prepared return envelope. The Charging Party will send the completed W-4 to Respondent for processing. Upon receipt of the W-4$2,080 in back pay, Respondent will confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇. Within 15 days of receipt, Respondent shall transmit payment to the Charging Party in the amount of $13,920 plus interest, less any withholding required by law, which constitutes back pay plus accumulated interest calculated at the IRS underpayment rate, compounded daily, daily through the Effective Date, less any withholdings required by law. IER will provide Respondent with payment instructions no later than five Within 15 business days from of the Effective Date, Respondent shall send all necessary tax forms Charging Party will need to complete to receive the back pay via email to the email address IER shall provide with instructions on how to submit the completed forms electronically. Within 30 days of receipt of Charging Party’s tax forms, Respondent shall make the payment to Charging Party. On the day of payment, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ to counsel for Respondent that payment was made, made and attach an image documentary evidence of the checksuch payment. 5. Within 45 days after remitting Except as set forth in Paragraphs 2 and 4, above, IER shall not seek from Respondent any additional monetary payment or civil penalty for any discrimination in violation of 8 U.S.C. § 1324b that is the Charging Party’s W-2 form for calendar year 2021 to subject of the Social Security Administration under IRS regulations, IER Charge and pursuant to the provisions of IRS Publication 957, IER Investigation through the Effective Date. 6. Respondent shall file a special report not disclose to the Social Security Administration allocating the payment made to any employer or prospective employer of the Charging Party in paragraph 4 any information or documentation related to the appropriate period. On IER Charge or the day Respondent submits the documentationIER Investigation unless requested by subpoena, Respondent shall confirm via email to ▇▇▇▇▇▇ ▇▇▇▇▇ at ▇▇▇▇▇▇.▇▇▇▇▇▇@▇▇▇▇▇.▇▇▇ and ▇▇▇@▇▇▇▇▇.▇▇▇ that such documentation was submitted and provide a copy of such documentationcourt order, or otherwise required by law. 67. In accordance with 8 U.S.C. § 1324b, Respondent shall not: (a) Discriminate discriminate on the basis of citizenship, immigration status status, or national origin in violation of 8 U.S.C. § 1324b. (b) Discriminate discriminate in the employment eligibility verification and reverification process. processes; Respondent shall not (i) refuse to honor documentation that on its face reasonably appears to be genuine, relates to the person, and satisfies the requirements of 8 U.S.C. § 1324a(b); (ii) not request more or different documents than are required by law; and (iii) fail to permit all employees to present any document or combination of documents acceptable by law both at initial hire and during any lawful reverification of continued employment authorization. (c) Intimidateintimidate, threaten, coerce, or retaliate against any person for their participation participating in this matter or the exercise of any right or privilege secured by 8 U.S.C. § 1324b. 78. If Respondent or its subsidiaries or agents engage in any employment eligibility verification activities during the term of the Agreement, Respondent shall comply with complete the E-Verify rules and responsibilities set forth under its Memorandum of Understanding with E-Verify and the M-775 E-Verify User Manual, shall not request that its employees present specific documents for the Form I-9 and/or E-Verify processes based on citizenship status or national origin, and shall not prohibit employees from working because they received a Tentative NonConfirmation result following tasks within 30 days prior to engaging in E-Verify.such employment eligibility verification activities: 8. Respondent shall not disclose to any employer or prospective employer of the Charging Party any information or documentation related to the Charging Party’s charge filed with IER. 9. Respondent shall (a) post an English and Spanish version of the IER “If You HaveHave The Right to Work” poster (“IER Poster”), in color and measuring no smaller than 8.5” x 11”, an image of which is available at ▇▇▇▇▇://▇▇▇.▇▇▇▇▇▇▇.▇▇▇/crt/worker- information#poster, in all places where notices to employees and job applicants are normally posted. The IER Poster will remain posted for the term of the agreement as long as Respondent or its subsidiaries or agents are engaged in employment eligibility verification activities;