Minor Compliance

Hiring and employing minors comes with an important responsibility—to ensure that the work minors perform is appropriate for their age, does not interfere with their education, and is safe. KBP does not employ anyone under the age of 15 as a matter of policy. Because all individuals under the age of 15 are not permitted to work for any KBP brand for any reason at any time, minors as referred to below are those employees ages 15, 16, and 17. KBP is committed to providing employees with a safe working environment free of recognized hazards and ensuring that minors are properly trained and supervised at all times. We subscribe to the following core values in our stores: Believing education is a significant priority—there is no question that education comes before employment. Providing flexible working hours to accommodate schedules. Taking a leading role in working with parents and minors should concerns arise. Supporting education by recognizing our employee’s scholastic achievements through various scholarship opportunities. Complying with all state, federal, and local laws, as well as Company policies, concerning the employment of minors. Summary of Restrictions on the Employment of Minors (Ages 15, 16, and 17) State and federal child labor laws establish specific requirements and regulations restricting the nature of the work performed by minors and limiting the hours minors can work in various ways. The hiring and employment of minors must comply with all applicable state, federal, and local laws and regulations, as well as the applicable provisions of KBP Food’s policies. Labor law restrictions with respect to all minors generally include, but are not limited to, the following: Must have all required minor work permission documentation—such as work permits, age certifications, and/or parental consents—before a minor starts work (including any training). Minors cannot operate a motor vehicle while doing business for KBP. Minors cannot be involved in maintenance work. Minors cannot be involved in any hazardous jobs, including operation or maintenance of hazardous power-driven equipment including meat slicers, mixers, power-driven machines, etc. Minors cannot be on a ladder. Must abide by restrictions on working hours for minors under state and federal laws. Must abide by all required break times and mealtimes for minors under state and federal laws. Minors must be paid at least the statutory minimum wage for all time worked, must be paid overtime as required by applicable laws and regulations, and must be paid for all time worked. Required Employment Documentation Most states require minors to provide a work permit or age certification before they begin any work (including any training). Some states also require signed parental consent or school administrator clearances. It may also be necessary for a minor to obtain new documentation at the beginning of each school year until the minor turns 18 or graduates from high school. Restaurant General Managers (“RGMs”)and Co-RGMs are advised to review the current status of all minors daily. RGMs and Co-RGMs must upload all state-required documentation to the minor’s employee record in Workday before the minor can begin training or perform any work. The original work permit, age certification, parental consent form, and/or school administrator clearance must also be retained in a secure location within the restaurant. If proper work authorization/required documentation is not received, RGMs and Co-RGMs may not place the minor on the schedule and should terminate the minor in Workday [with “did not provide documentation” as the term code/reason]. Scheduling Restrictions There are several restrictions under federal and state laws with respect to the number of hours minors can work, the days a minor can work during the week, and the time of day that minors can work. 15-year-old employees 15-year-old employees are prohibited from working: During school hours; More than 3 hours per day during the week; Before 7:00 a.m. or after 7:00 p.m. (except June 1 through Labor Day in most states, during which time the evening work hours are extended to 9:00 p.m.); More than 8 hours per day on Saturdays and Sundays; More than 5 continuous hours without receiving a 30-minute break in nearly all states (please see the State Addenda to determine if your state has a stricter standard); and More than 16 hours each week in nearly all states (please see the State Addenda to determine if your state has a stricter standard). As with all other aspects of this policy, you are required to review, understand, and comply with all of the restrictions set forth in the State Addendum and summary spreadsheet for the state where you work. 16- and 17-year-old employees Restrictions on the number of hours, number of days per week, and time of day that employees ages 16 and 17 can work vary depending on the state where you work. As with all other aspects of this policy, you are required to review, understand, and comply with all of the restrictions set forth in the State Addendum and summary spreadsheet for the state where you work. Break and Wage Requirements All employees must comply with federal and state laws and regulations regarding rest and meal periods. In most states, if a 15-year-old minor employee works more than 5 hours continuously, a 30-minutes break is required no later than 5 hours into their shift. With respect to 16- and 17-year-old minor employees, see the relevant State Addendum for break requirements. Break times must be documented and included in the schedule. Employees are required to clock themselves in and out for all breaks of 30 minutes or more. Employees should accurately observe and record meal and rest periods in our time keeping system. Under no circumstance should minors skip a meal or break period. There are no exceptions to this requirement. Employees should check with their supervisor regarding procedures and schedules for rest and meal breaks. RGMs and Co-RGMs ultimately are responsible to ensure breaks are applied and managed according to this policy. Minors must be paid at least the statutory minimum wage for all time worked. See Minimum Wage Schedule. Minors must also be paid overtime as required by laws and regulations. In addition, minors must be paid for all time worked. There are no exceptions to these requirements. Additional Restrictions Specific to 15-Year-Old Employees There are several additional unique restrictions and requirements regarding the employment of 15-year-olds. These include the following. Special Workplace Safety Requirements KBP is committed to ensuring that when all minors work, the duties they perform are safe and do not jeopardize their health, well-being, or educational opportunities. 15-year-olds are prohibited from working with certain equipment or performing hazardous jobs. The duties they are prohibited from performing include the following: Prohibited Duties: Cleaning, working with, or touching: The Bunn hot water machine The bun toaster Grills on the Taco Bell line Fryers Working in the cooler or freezer, including prep work Working with any equipment not specifically approved Absolutely no frying or grilling is allowed! Acceptable Duties: Greet customers and obtain orders Perform cashiering duties Provide drive-thru support Make beverages Pack orders Bag and carry out customer orders Cleanup work (wiping tables, sweeping floors, cleaning restrooms, picking up trash in the parking lot, washing dishes, etc.) Prep work in the kitchen area only Prep sides by using the microwave These lists are not intended to be exhaustive. If you have questions about a particular piece of equipment or duty, reach out to your supervisor or Human Resources. Ensuring Compliance with Federal and State Laws Area Coaches, RGMs, and Co-RGMs are required to comply with all federal, state, and local child labor laws and to ensure that all employed minors have proper authorization/certifications and are not working outside the hours, days, and timeframes permitted by law, or performing any prohibited tasks. Area Coaches, RGMs, and Co-RGMs must also ensure electronic and in-store recordkeeping requirements are being met, relevant policies followed, and records maintained (including the display of child labor posters in a place that is easy for employees to see on a regular basis, and maintaining in restaurants minor work permits and other state-specific documentation and forms). It is important to note that several states have stricter laws in place than those imposed by federal law. When federal and state laws/regulations/standards differ, the laws/regulations/standards that are most restrictive (i.e., that offer the most protection for minor employees) will apply. Therefore, it is imperative that Area Coaches, RGMs, and Co-RGMs are aware of and comply with the child labor laws of the state in which they work. Please see the State Addendum(s) for guidance regarding your state. If you have any questions at any time regarding federal, state, or (where applicable) local restrictions on minor employment, please contact Human Resources as soon as possible to ensure that you and others understand and are in compliance with this policy. Non-Compliance, Policy Violations, and Disciplinary Action If an employee does not comply with this policy, disciplinary action may be taken, up to and including termination of employment. KBP has a progressive disciplinary policy that is administered based on the facts and circumstances of each particular situation. Factors that KBP considers in determining the appropriate disciplinary response for a failure to comply with this policy vary depending on the facts and circumstances and often include, but are not limited to, the following: Type/nature of violation(s) Seriousness of the violation(s) Number of instances of non-compliance Circumstances surrounding the violation(s), including, but not limited to: The employee’s role in the violation(s); Whether the employee has management or supervisory responsibilities. Whether the employee is the manager or supervisor of the minor at issue; Whether the employee had knowledge of the violation(s) at the time it occurred; The existence of a pattern of non-compliance or blatant disregard of minors or this policy by the employee with respect to the non-compliance; and Any harm to the minor caused by the non-compliance Past history of policy non-compliance by the employee, including a consideration of the factors referenced above with respect to any prior policy non-compliance The employee’s acceptance of responsibility for the non-compliance and commitment to compliance in the future The types of discipline administered for failure to comply with this policy can include, but are not limited to, the following: Verbal warning Written warning Additional training and policy review Performance improvement plan with achievement of milestones Demotion (Area Coaches/RGMs/Co-RGMs/other supervisors) or other reductions in responsibilities Cancelation of and/or reduction in work shift(s) Reduction in pay Suspension Termination As explained above, the level of corrective action warranted will be based on the facts and circumstances of each situation. For example, an unintentional mistake, such as when a minor stops work before a required work-stop deadline, forgets to clock out before the deadline, but clocks out as soon as the minor or the minor’s supervisor realizes that fact, may warrant a lesser level of corrective action, such as a reminder to the minor and supervisor (depending on the circumstances) that they should focus on, and comply with, clock-out procedures in the future. Flagrant and/or repeated violations, such as a pattern and practice of scheduling minors past permitted working time periods, asking minors to work outside of permitted time periods, or allowing a minor to work without proper documentation would likely result in more severe sanctions, up to and including termination, depending on the circumstances. In any situation where an Area Coach, RGM, Co-RGM, or other employee with supervisory responsibilities is disciplined under the progressive discipline policy, the disciplined employee will be required to re-review this policy, complete training administered by Human Resources regarding minor employment practices, and re-certify that they understand the policy, related procedures, and will comply with them in the future. Multiple violations by an Area Coach, RGM, Co-RGM, or other employee with supervisory responsibilities may result in a prohibition on the employment of minors at the disciplined employee’s restaurant(s), demotion of the disciplined employee, termination, or the discipline of others—including discipline of the employee’s supervisor and other more senior supervisory employees—if warranted. Should an employee see or hear of any violations of this policy, or have concerns about KBP’s practices, they should report those concerns to their supervisor and/or Human Resources Hotline at 1-888-971-2991 or hrsupport@kbpbrands.com.

		09.2023