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Timekeeping Policy (US) Operations Revised 07/22/2021 1 Overview The Timekeeping Policy is designed so that all information pertaining to breaks, meals, scheduling, time off, pay rules, and other information that affects employee hours and pay is included in one location for easy reference. This policy complements the Scheduling Policy. Managers are encouraged to review labor law posters in the store in the event there is an update to the law prior to a new policy being issued. The information can be found in the following order: 1. Employee Status 2. Active Employee Requirements 3. Timekeeping Records 4. Rest Breaks and Meal Periods 5. Nursing Mothers Requirements 6. Day of Rest/Time Off 7. Overtime Regulations 8. Holiday Pay 9. Deferred Days Off 10. Jury Duty 11. Travel Time Pay 12. Lateness/Sick Reporting 13. Emergency Closing 14. Payment for Minimum Hours Worked 15. Unscheduled Shifts 16. California Split Shift Pay 17. New York Spread Shift and Split Shift Penalty 18. Dimensions Mobile App 1. Employee Status Employee status is based on job responsibilities, compensation and the number of hours scheduled and worked: Full-Time Salaried/Exempt: positions that qualify as Salaried/Exempt are exempt from the minimum wage and overtime requirements of the Fair Labor Standards Act (FLSA) and applicable state law. To qualify for this exemption, employees generally must meet certain job duties tests and be paid on a salary basis in an amount required by law. Salaried, full-time employees are eligible for all full-time benefits offered by the Company. Full-Time Hourly/Non-Exempt: the minimum wage and overtime requirements of the FLSA apply

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Timekeeping Policy (US) Operations

Revised 07/22/2021 1

Overview The Timekeeping Policy is designed so that all information pertaining to breaks, meals, scheduling, time off, pay rules, and other information that affects employee hours and pay is included in one location for easy reference. This policy complements the Scheduling Policy. Managers are encouraged to review labor law posters in the store in the event there is an update to the law prior to a new policy being issued. The information can be found in the following order: 1. Employee Status 2. Active Employee Requirements 3. Timekeeping Records 4. Rest Breaks and Meal Periods 5. Nursing Mothers Requirements 6. Day of Rest/Time Off 7. Overtime Regulations 8. Holiday Pay 9. Deferred Days Off 10. Jury Duty 11. Travel Time Pay 12. Lateness/Sick Reporting 13. Emergency Closing 14. Payment for Minimum Hours Worked 15. Unscheduled Shifts 16. California Split Shift Pay 17. New York Spread Shift and Split Shift Penalty 18. Dimensions Mobile App 1. Employee Status Employee status is based on job responsibilities, compensation and the number of hours scheduled and worked:

• Full-Time Salaried/Exempt: positions that qualify as Salaried/Exempt are exempt from the

minimum wage and overtime requirements of the Fair Labor Standards Act (FLSA) and applicable state law. To qualify for this exemption, employees generally must meet certain job duties tests and be paid on a salary basis in an amount required by law. Salaried, full-time employees are eligible for all full-time benefits offered by the Company.

• Full-Time Hourly/Non-Exempt: the minimum wage and overtime requirements of the FLSA apply

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to employees who are classified as Full-time Hourly/Non-Exempt. o Full-time hourly employees are scheduled and regularly work over 30 hours a week on average. o Full-time hourly employees are eligible for all full-time benefits offered by the Company. o Full-time hourly employees may not work less than 30 hours per week for 8 consecutive weeks

or 4 consecutive pay periods, without being changed to part-time status.

• Part-Time Hourly/Non-Exempt: the minimum wage and overtime requirements of the FLSA apply to employees who are classified as Part-Time Hourly/Non-Exempt. o Part-time employees are scheduled and regularly work less than 30 hours a week on average. o Generally, part-time employees are not eligible for medical benefits and paid time off, except as

required by law. Please see the applicable benefits and paid time off policies for further information.

o Part-time employees may not work more than 30 hours per week for 8 consecutive weeks or 4 consecutive pay periods without being offered full-time status.

• Part-Time or Full-Time Temporary: Seasonal or temporary employees are hired for a defined period of time (not to exceed 90 days) for peak periods such as holiday, back to school, or resort season, to cover a leave of absence, or for some other short-term assignment. o Temporary employees may be either part-time (working less than 30 hours per week) or full-

time (working greater than 30 hours per week). o Temporary employees are not eligible for vacation time but may be eligible for sick leave

depending on state/local law. Temporary employees are eligible for the 401(k) Plan and, depending on the amount of time they work, they may be eligible for medical benefits. Please refer to the applicable policies and controlling plan documents.

o The employee status may be changed to “regular” at any time, but in any event, a temporary employee must be reclassified or terminated by the end of the 90-day time period.

o If a temporary employee’s status changes to “regular”, the hours or time worked as a temporary employee count toward benefit eligibility requirements for vacation, medical benefits, holiday pay, etc.

2. Active Employee Requirements • An employee must normally be scheduled to work a minimum of one 4-hour shift per pay period.

Due to business trends, vacations or holiday, the store may not be able to meet this scheduling requirement.

• An employee MUST work a minimum of one, 4-hour shift within a 30-day period. • Employees who do not meet these requirements must be terminated.

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3. Timekeeping Records Clocking In and Out Urban Outfitters, Inc. is committed to ensuring that employees are paid for all compensable time worked, and as such has a zero-tolerance policy for timecard fraud.

• Employees must accurately record all hours worked in our timekeeping system, Dimensions. • Employees are not permitted to clock in or out for a co-worker, or to falsify timekeeping records in

any way. • Salaried/Exempt Employees are required to clock in at the start of their shift each day. • Hourly/Non-Exempt Employees are required to clock in when they begin working and to clock out

when they stop working. As outlined in the Rest Breaks and Meal Periods section below, Hourly/Non-Exempt Employees must also clock out at the beginning of a meal period and clock in when the meal period is over.

If Dimensions is not working or you forget to clock in or out, alert a Manager as soon as the error is realized. Consistent failure to clock in or out may result in corrective action, up to and including termination of employment. Working Off-the-Clock All Urban Outfitters, Inc. Hourly/Non-Exempt Employees must be compensated for all time worked. Managers and supervisors are prohibited from directing Hourly/Non-Exempt Employees to perform any off-the-clock work; this includes working before clocking in for your scheduled shift, working after clocking out for your scheduled shift, or working during a meal or rest period. Prior Manager approval is required for an Hourly/Non-Exempt Employee to work outside of their regularly scheduled shift (for example, contributing to Brand social media, completing performance reviews). All hours worked outside of an employee’s regularly scheduled shift must be accurately recorded in Dimensions and, depending on state and federal overtime regulations, must be paid at the appropriate overtime rate. 4. Rest Breaks and Meal Periods Recognizing that it is important for employees to take time during their shifts to rest and recharge, the Company provides meal periods and rest breaks to all employees in accordance with federal, state, and local law. States with specific break policies are listed below the Company guidelines. State laws supersede the Company guidelines. It is management’s responsibility to ensure that the appropriate breaks are offered to employees and that breaks are not interrupted.

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• Under no circumstances can employees choose to work through their meal periods. • Meal periods must be taken; an employee cannot skip a meal period to shorten their workday. • Meal periods must always be taken in a timely manner. For direction on when meal periods must be

taken, read the specific requirements listed below and consult the labor law posters in your store. • Employees must be relieved of all duties during meal periods. • Meal periods are unpaid unless otherwise required by law. Employees must remember to clock out for

meal periods at the time they take any meal period, and to clock back in on time at the end of any meal period.

• Employees must take their rest breaks. Rest breaks are paid breaks, so employees must not clock out for their rest breaks.

• Meal periods and rest breaks cannot be combined. Rest Break Requirements Employees do not clock out for Rest Breaks. Employees entitled to 10-minute rest breaks should take their first rest break approximately 2 hours into their shift. Subsequent rest breaks should be taken approximately every 4 hours thereafter.

Total Shift Length (including meal periods & rest breaks)

Rest Break (Paid)

0 to 3.5 hours No Rest Break 3.6 to 6.0 hours One 10-minute Rest Break 3.6 to 6.0 hours (Maryland) One 15-minute Rest Break 6.1 to 8.0 hours Two 10-minute Rest Breaks

8.1 to 10.0 hours Two 10-minute Rest Breaks

10.1 to 12.0 hours Three 10-minute Rest Breaks Meal Period Requirements Employees Clock out for Meal Periods. In the states of California, Colorado, North Dakota, New Hampshire and Washington, employees receive an unpaid 30-minute meal period for any shift longer than 5 hours. In Tennessee, employees receive an unpaid 30-minute meal period for 6-hour shifts. In all other locations, employees receive an unpaid 30-minute meal period for any shift longer than 6 hours or a 60-minute meal period for shifts greater than 8 hours.

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Total Shift Length

(including meal periods & rest breaks) Meal Period (Unpaid)

0 to 3.5 hours No Meal Period

3.6 to 5.0 hours No Meal Period

5.1 to 6.0 hours (CA, CO, ND, NH, & WA*) One 30-minute Meal Period*

6.0 hours (TN) One 30-minute Meal Period

6.1 to 8.0 hours One 30-minute Meal Period**

8.1 to 10 hours One 60-minute Meal Period Second Meal Period: * In CA, CO, ND, NH, and WA, employees are entitled to an unpaid meal period for every period of more

than five consecutive hours worked. As a result, some employees may be entitled to a second meal period. This second meal period must begin no later than 5 hours after the end of their previous meal period, and must be at least 30 minutes in length.

New York stores: Anyone who works 6 or more hours between the hours of 11am and 2pm must be given a 30-minute Meal Period between the hours of 11am and 2pm. Every person employed for a shift starting before 11am and continuing later than 7pm, must be given an additional meal period of at least 20 minutes between 5pm and 7pm. Every person employed for a period or shift of more than 6 hours starting between the hours of 1pm and 6am, shall be allowed at least 45 minutes for a Meal Period at a time midway between the beginning and end of the shift.

** Employees are entitled to an unpaid meal period for every period of more than six consecutive hours

worked. As a result, some employees may be entitled to a second meal period. This second meal period must begin no later than 6 hours after the end of their previous meal period, and must be at least 30 minutes in length.

Sample Shifts Managers may use the sample shifts listed below to assist in generally interpreting the Rest Break and Meal Period requirements. However, managers are encouraged to confirm that these examples comport with state and local law by reviewing the labor law notices posted in their store.

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Rest Breaks Employees DO NOT CLOCK OUT for Rest Periods

Shift Length 4 hours 5 hours 6 hours 7 hours 8 hours 10 hours Time 3 – 7pm 3 – 8pm 3 – 9pm 2 – 9pm 1 – 9pm 12 – 10pm All States 10 min

5:00 – 5:10pm

5:00 – 5:10pm

5:00 – 5:10pm

4:30 – 4:40pm

1st 3:00 – 3:10 pm 2nd 7:00 – 7:10pm

1st 3:00 – 3:10pm 2nd 7:00 – 7:10pm

Maryland 15 min

5:00 – 5:15pm

5:00 – 5:15pm

5:00 – 5:15pm

4:30 – 4:45pm

1st 3:00 – 3:10pm 2nd 7:00 – 7:10pm

1st 3:00 – 3:10pm 2nd 7:00 – 7:10pm

Meal Periods

Employees CLOCK OUT for Meal Periods Shift Length 4 hours 5 hours 6 hours 7 hours 8 hours 10 hours Time 3 – 7pm 3 – 8pm 3 – 9pm 2 – 9pm 1 – 9pm 12 – 10pm All states None None None 6:00 –

6:30pm 5:30 – 6:00pm

5:00 – 6:00pm

CA, CO, ND, NH, WA, TN

None None 6:30 – 7:00pm

6:00 – 6:30pm

5:30 – 6:00pm

5:00 – 6:00pm

CA Rest Break and Meal Period Penalty If an employee is not provided with a timely 10-minute paid rest break or if the employee’s 10-minute paid rest break is interrupted, the employee is entitled to one hour of pay at their regular rate as a penalty (Rest Break Penalty). Employees who are entitled to a Rest Break Penalty are obligated to inform their manager through Dimensions’ attestation module at CLOCK OUT. The manager will investigate claims of missed or interrupted rest breaks and either approve or reject the Rest Break Penalty during daily processing. If the results of the investigation are such that the Rest Break Penalty is rejected, the manager must document the reason for the denial in Dimensions. Even if two rest breaks are missed during the day, there is only one Rest Break Penalty per day per employee. If an employee does not receive their 30-minute unpaid meal period by the end of their fifth hour or if their meal period is interrupted, the employee is entitled to one hour of pay at their regular rate as a penalty (Meal Period Penalty). The first meal period must begin before the employee has worked five hours. For example, if an employee works 7:00am – 4:00pm, the first meal period must begin no later than 11:59am. The chart below illustrates how time worked corresponds to the first hour, second hour and so on for purposes of when the meal period must be taken:

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Time Worked Hour 7:00am – 8:00am 1st hour 8:00am – 9:00am 2nd hour 9:00am – 10:00am 3rd hour 10:00am – 11:00am 4th hour 11:00am – 12:00pm 5th hour (first meal period must begin before the

employee works five hours or no later than 11:59am) Employees who are entitled to a Meal Period Penalty are also obligated to inform their manager through Dimensions’ attestation module at CLOCK OUT. The manager will investigate claims of missed or interrupted meal periods and either approve or reject the Meal Period Penalty during daily processing. If the results of the investigation are such that the Meal Period Penalty is rejected, the manager must document the reason for the denial. Even if an employee fails to report a Meal Period Penalty through Dimensions’ attestation module, the timekeeping system will identify Meal Period Penalties which may be triggered based on the employee’s punches. Meal Period Penalties which are identified through this process will be automatically routed to the manager for approval or rejection. For example, an employee is scheduled to work from 7:00am to 4:00pm. The employee clocks in at 7:00am and takes their meal period at 12:30pm. The employee is entitled to a Meal Period Penalty because the meal period did not begin before the end of the employee’s fifth hour of work (i.e., before 11:59am). Dimensions will automatically apply the Meal Period Penalty to the employee’s timecard and send to the manager for approval. An employee who works no longer than six hours may waive receipt of an unpaid meal period and is not entitled to a Meal Period Penalty. The employee acknowledges that they have waived their meal period through Dimensions’ attestation module at CLOCK OUT. Additionally, if an employee works longer than ten hours and does not receive their second 30-minute unpaid meal period or if their meal period is interrupted, the employee is entitled to one hour of pay at their regular rate as a penalty (Meal Period Penalty). Employees who work no longer than twelve hours may waive receipt of the second unpaid meal period and are not entitled to a penalty, but may only do so if they did not waive the first meal period. 5. Nursing Mothers Requirements Urban Outfitters, Inc. shall provide a reasonable unpaid break time for an employee to express breast milk for her nursing child for one year after the child’s birth and a place, other than a bathroom, that is shielded from

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view and free from intrusion from co-workers and the public, which may be used by an employee to express breast milk (i.e., a fitting room or manager’s office). When the room is in use for lactation purposes, a sign should be placed on the door to notify other employees that the space is occupied. Privacy Signage is available on the Company intranet. To the extent possible, lactation breaks can run concurrently with any unpaid or paid break time already provided to the employee unless otherwise noted below.

State/City

California

• Must provide a reasonable amount of break time to accommodate an employee desiring to express breast milk for the employee’s child each time the employee has need to express milk (referred to as a lactation accommodation).

• The Company will provide a lactation room or other designated space (e.g., manager’s office, fitting room) that may be used to express breast milk. The lactation room must be a sanitary place, other than a restroom, shielded from view and free from intrusion and that has an electrical outlet, a chair, a surface on which to place a breast pump and other personal items, and nearby access to running water. The Company will also provide a refrigerator suitable for breast milk storage in reasonable proximity to the employee’s work area.

• Employees who need to use the designated space to express breast milk will be given priority use of the space. When the room is in use for lactation purposes, a sign should be placed on the door to notify other employees that the space is occupied. Please use the Privacy Signage available on the Company intranet.

• Employees have a right to request a lactation accommodation. Such requests may be directed to the employee’s manager or the Sr. HR Manager. Requests for lactation accommodation will be responded to within 5 business days.

• If an employee’s lactation accommodation request poses an undue hardship on the Company, the employee’s manager or the Sr. HR Manager will discuss reasonable alternatives with the employee to accommodate the employee’s needs.

• Retaliation against an employee for exercising their rights under Chapter 720 of the Labor Code is prohibited. An employee has the right to file a complaint with the Labor Commissioner for any violation of their rights under this chapter.

Colorado Must allow lactation breaks for up to two years after the child’s birth.

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State/City

Illinois

• An employer shall provide reasonable break time to an employee who needs to express breast milk for her nursing infant child each time the employee has the need to express milk for one year after the child's birth.

• Lactation breaks may run concurrently with any paid or unpaid break time already provided to the employee.

• Lactation breaks taken during a regularly scheduled unpaid break (for example, during the employee’s 30-minute unpaid meal period) are not paid. Any additional breaks taken for the purpose of expressing milk or nursing a baby will be paid.

Indiana

To the extent possible: • Lactation breaks shall run concurrently with any paid or unpaid break time

already provided to the employee; and • The Company must take reasonable measures to provide a refrigerator or

other cold storage space for keeping milk that has been expressed, or allow the employee to provide their own portable cold storage device for keeping milk that has been expressed until the end of the employee’s work day.

Maine Must allow lactation breaks for up to three years after the child’s birth.

New York

Must allow lactation breaks for up to three years after the child’s birth. NYC Stores – Lactation Accommodation Policy: • Employees have a right to request a lactation accommodation. Such

requests may be directed to the employee’s manager or the Sr. HR Manager. Requests for lactation accommodation will be responded to within 5 business days.

• If an employee’s lactation accommodation request poses an undue hardship on the Company, the employee’s manager or the Sr. HR Manager will discuss reasonable alternatives with the employee to accommodate the employee’s needs, initiating a cooperative dialogue as required under NYC Local Law 186.

• A reasonable amount of break time will be provided to an employee to express breast milk.

• The Company will provide a lactation room or other designated space (e.g., manager’s office, fitting room, art room) that may be used to express breast milk. The lactation room must be a sanitary place, other than a restroom, shielded from view and free from intrusion and that has an electrical outlet, a chair, a surface on which to place a breast pump and

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State/City other personal items, and nearby access to running water. The Company will also provide a refrigerator suitable for breast milk storage in reasonable proximity to the employee’s work area.

• Employees who need to use the designated space to express breast milk will be given priority use of the space. When the room is in use for lactation purposes, a sign should be placed on the door to notify other employees that the space is occupied. Please use the Privacy Signage available on the Company intranet.

• When more than one employee needs to use the lactation room at the same time, the manager should discuss alternative options with the employees. This may include finding an alternative space or creating a schedule for use of the lactation room.

Oregon Must provide a reasonable amount of break time to express breast milk each time the employee has a need to express breast milk for up to 18 months after the child’s birth.

Vermont Must allow lactation breaks for up to three years after the child’s birth 6. Day of Rest/Time Off Urban Outfitters, Inc. tries to schedule full-time employees for a 5-day work week. Due to the nature of the business, there may be times throughout the year where an employee may be requested to work 6 days during a single week. Because many of the stores are open seven days a week, certain states recognize an employee’s right to choose a day for religious observation. The Company complies with all state and federal laws regarding days off. It is management’s responsibility to ensure that employees are scheduled according to individual state guidelines.

State

California

Every person is entitled to one day’s rest every 7 days. When the nature of the employment reasonably requires that the employee work 7 or more consecutive days, the accumulation of the equivalent of 1 day rest per week must be given in each calendar month.

Connecticut No employee must be required to work more than 6 days in any calendar week. No person who states that a particular day of the week is observed as his Sabbath may be required to work on such day.

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State

Illinois

Every employer shall allow every employee at least 24 consecutive hours of rest in every calendar week, in addition to the regular period of rest allowed at the close of each working day. This does not apply to part-time employees whose total work hours for one employer during a calendar week do not exceed 20, or to employees employed as watchmen or security guards.

Kentucky Requires at least one (1) day of rest each calendar week for each employee.

Maryland

An employee in a retail establishment may choose, as a day of rest, Sunday or the Sabbath of the employee. An employee who chooses a day of rest shall give written notice to the employer, and during the course of employment, may change the day of rest by giving written notice of the change to the employer at least 30 days before its effective date. If an employer compels an employee to work on the day of rest that the employee chooses, the employee is entitled to bring an action against the employer to recover 3 times the regular rate of pay of the employee for each hour the employee works on that day.

Massachusetts Employers must provide employees with 24 consecutive hours of rest in each 7 consecutive days. The day of rest must include an unbroken period between 8 am and 5 pm.

New Hampshire Employers that require employees to work on Sundays must provide 24 consecutive hours off during the next 6 days.

New York Employers must provide employees with at least 24 consecutive hours of rest per calendar week.

North Dakota

An employer may not require an employee to work seven consecutive days in a business that sells merchandise at retail. An employer may not deny an employee at least one period of twenty-four consecutive hours of time off for rest or worship in each seven-day period.

South Carolina

An employee cannot be required to work before 1:30pm on a Sunday if they notify the employer of their need to worship during that time. Any employee of any business which operates on Sunday has the option of refusing to work before this time.

Texas An employer may not require an employee to work seven consecutive days in an establishment, the business of which is selling merchandise at retail.

Wisconsin 24 consecutive hours of rest in each calendar week must be given.

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7. Overtime Regulations Urban Outfitters, Inc. adheres to all state and Federal requirements for overtime and double-time regulations.

• Unless specific state rules apply, overtime is calculated as time worked over 40 hours in a single week for all overtime eligible positions.

• Actual hours worked are used for overtime calculation; benefit hours such as vacation, sick days and holidays do not count as “hours worked” for overtime.

• Hours cannot be adjusted from week to week within the pay period to avoid overtime. • For Non-Management Employees, overtime should be approved in advance by a Manager. Hours

worked must always be paid regardless of whether an employee was authorized to work. However, repeated failure to obtain prior approval for unscheduled work may result in disciplinary action.

• Hourly Management Employees should use their best judgment in determining how best to support the business with respect to overtime and scheduling.

State Overtime Type Calculation

ALL STATES Weekly

One and one-half times the employee's regular rate of pay for all hours worked in excess of 40 hours in a workweek. Only straight-time hours apply toward computing overtime for hours worked in excess of 40 in a week. Daily overtime hours, paid at time-and-one-half the regular rate of pay, do not count toward the 40-hour weekly limit. Only work hours actually worked count toward overtime computation. Hours excluded from computation of overtime include: vacation, holidays, sick leave, jury duty, and other paid time that is not actually worked.

California

7th Day

One and one-half times the employee’s regular rate of pay must be paid for the first 8 hours worked on the 7th consecutive day of work in the Company’s designated work week of Sunday – Saturday.

Daily One and one-half times their regular rate for work exceeding 8 hours in a day or 40 hours in a week.

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State Overtime Type Calculation

Double-time Double-time is required for hours worked in excess of 12 hours on any workday or in excess of 8 hours on the seventh day within the same work week.

Colorado Daily One and one-half times their regular rate for work exceeding 12 hours in a day or 40 hours in a week.

Kentucky 7th Day Employees who work 7 days in any one workweek must be paid one and one-half times their regular rate of pay for time worked on the 7th day.

Massachusetts

Sunday 1.2 times their regular rate for hours worked on Sundays.

Designated holidays

Columbus Day and Veterans Day are paid at the overtime rate. Employees do not earn holiday pay. * Refer to the “Holiday Pay” section for additional guidance regarding Veterans Day.

Nevada

Daily/Weekly

If the employee’s hourly rate is less than one and one-half times the minimum wage, then overtime is calculated at one and one-half times the employee’s regular rate for time worked over 8 hours in a 24-hour period or over 40 hours in a week.

Weekly

If the employee’s hourly rate is more than one and one-half times the minimum wage, then overtime is calculated at one and one-half times the employee’s regular rate for time worked over 40 hours in a week.

Rhode Island

Sunday

One and one-half times their regular rate for hours worked on Sundays Sunday hours at overtime do not count toward weekly hours worked for overtime calculation.

Designated holidays Victory Day, Labor Day, Columbus Day, and Veterans Day are paid at the overtime rate. Employees do not earn holiday pay.

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Exemption from Overtime Classification Management positions that are classified as exempt from overtime require, among other things, that the employee primarily engage in management activities. Any employee who is classified as exempt due to their managerial role but who does not regularly engage in management activities at least 50% of the time must notify their manager/supervisor that they are not meeting the expectation for the Exempt classification. Exempt employees also must receive their full salary for any week in which they perform any work, without regard to the number of days or hours worked. However, Exempt employees need not be paid for any workweek in which they perform no work at all for the Company. Deductions from Salary Deductions from pay for any of the following reasons in a week in which an exempt employee performs any work are prohibited by the Fair Labor Standards Act (FLSA):

• Jury duty; • Attendance as a witness; • Temporary military leave; • Absences caused by the Company or the operating requirements of the business; • Partial day absences, other than those specifically listed below.

Managers or supervisors violating this policy will be subject to disciplinary action up to and including termination. Deductions from pay for any of the following reasons in a week in which an Exempt employee performs any work are permitted:

• Absences of one or more full days for personal reasons (partial days will be paid at the full daily rate of pay);

• Absences of one or more full days due to sickness or disability where the employee is in the waiting period for vacation and sick leave or where the employee has exhausted their vacation or sick leave;

• Fees received by the employee for jury or witness duty or military leave may be applied to offset the pay otherwise due. However, no deductions will be made for failure to work for these reasons;

• Penalties, in any monetary amount, imposed by the Company for infractions of safety rules of major significance, as determined by the Company;

• Deductions for the first and last week of employment, when only part of the week is worked by the employee;

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• Deductions for unpaid leave of any length taken pursuant to the Family and Medical Leave Act. Employees who believe their pay has been improperly reduced should contact the Sr. HR Manager immediately to request an investigation. Any such employee will be asked to specify in writing the circumstances of the pay deduction and whether it has occurred on other occasions. If the deduction was, in fact, improper, the Company will reimburse the employee as promptly as possible, but in no case longer than two pay periods after confirmation of the problem by the Company. No employee will suffer an adverse employment action or retaliation for making a good faith complaint about their wages, or improper deductions from them. 8. Holiday Pay Holiday The following 7 holidays are observed by Urban Outfitters, Inc.

New Year’s Day Martin Luther King Jr. Day Memorial Day

Independence Day

Labor Day Thanksgiving Christmas

Employees who wish to observe holidays not recognized by the Company may use vacation days. The Director of Retail or Regional Brand Director together with the District Brand Leader and store management will determine if business conditions and local customs dictate that a store be open or closed on a particular holiday. Eligibility for Holiday Pay

• All salaried employees are eligible for holiday pay immediately upon hire. • All full-time hourly employees are eligible for holiday pay after they have been employed for 90 days. • San Francisco part-time employees are eligible for holiday pay after they have been employed for 90

days. • Part-time and temporary employees are not eligible for holiday pay unless otherwise required by

applicable law. • Employees who change from part-time to full-time are eligible for holiday pay immediately as long as

they have been employed 90 days. • All hourly employees who work on the holiday (whether part-time or full-time) are paid time-and-a-

half for hours worked. • Massachusetts stores: eligible employees scheduled to work on Veterans Day who request time off

to participate in Veterans Day exercises may be entitled to paid leave. To be eligible, the employee

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must (a) be scheduled to work on Veterans Day, (b) be a veteran or a member of a department of war veterans (as defined by Massachusetts law), and (c) provide reasonable notice for such leave.

Paying Employees during a Holiday Week

Status Works the holiday Does not work the holiday

Salaried Receives another day off that week or a deferred holiday day (see below).

Receives the day off in addition to their regularly scheduled days off that week.

Full-Time Hourly

Receives time-and-a-half for hours worked and after 90 days, receives an *average day’s holiday pay.

After 90 days receives an *average day’s holiday pay.

Part-Time Hourly

Receives time-and-a-half for hours worked. Does not receive holiday pay.

San Francisco Part-Time

Receives time-and-a-half for hours worked. After 90 days receives an *average day’s holiday pay.

*Average Day is based on the average day worked over the last 4 weeks. Reporting of Holidays All holidays are automatically programmed into Dimensions and will populate 30 days prior to the holiday.

• Holiday pay for salaried employees will be added to their “Holiday” balance under Accruals. • Full-time hourly employees who have worked 90 days or more will automatically receive an average

day’s holiday pay. • Part-time or temporary employees, excluding San Francisco, will not be paid for the holiday, but will

receive time and a half for hours worked. • Holiday pay does not count as hours worked for overtime purposes.

o For example: If an employee works 34.5 hours in one week and is paid 8 holiday hours, the total number of hours they will be paid for is 42.5 hours. The 2.5 hours are paid at the regular hourly rate because the employee did not actually work over 40 hours.

Deferred Holiday Salaried employees who are working on the holiday have the option of deferring their holiday. The employee should receive 3 days off that week (2 regularly scheduled days off plus a day for the holiday). If the employee cannot take 3 days off that week, a deferred holiday day off may be scheduled during a different week with the permission of their District Brand Leader.

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• Every effort should be made to give all salaried employees 3 days off during a holiday week. The District Brand Leader should always be consulted to help resolve scheduling difficulties.

• The salaried employee may schedule the deferred holiday on the holiday or up to 60 days after the holiday.

o California stores: there is no expiration on when the employee may schedule the deferred holiday.

• At no time may the deferred holiday day be paid out in lieu of time off. • Holiday hours are redeemed by adding the DHOL Taken to the schedule or timecard. • Employees who take the holiday hours on the actual holiday must add DHOL Taken to that day.

For further documentation on the Deferred Holiday process, please refer to the Dimensions Manager’s Guide and Dimensions Manager’s Basic Scheduling Guide (BHLDN & Terrain). 9. Deferred Days Off There are specific times of the year when Salaried employees are eligible to earn deferred days off.

• If a Salaried employee is unable to take their normally scheduled 2 days off during a week, the employee should be scheduled for a deferred day off at a later time (i.e. the two weeks at Christmas when managers may be required to work six days; one deferred day is earned for each week, for a total of two deferred days).

• In Dimensions, on the day the employee is taking the deferred day off, a manager should punch them in for that day and attach the comment “Deferred Day Off”.

• Deferred days off must be scheduled within 30 days from the time they are earned. Employees may not be paid in lieu of taking the deferred days off.

Termination • In the event of resignation, when two weeks’ notice is given and the employee continues to perform

work during the notice period, deferred day pay will be paid upon termination. • In the case of termination, deferred day pay will be paid upon termination. • Deferred days may not be taken as part of the two-week notice period.

10. Jury Duty This policy applies to Jury Duty only. It does not apply to other court appearances, such as a response to a subpoena, unless otherwise required by applicable law. The employee should use vacation time or arrange for their day off for these other types of court appearances.

• Employees must inform their manager as soon as they receive “notice” of Jury Duty. • Employees must check with their manager to determine whether their absence would create a

hardship and, if so, they or the Company can take steps with the appropriate jurisdiction to defer or

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delay the serving. • Up to a maximum of 40 hours (not to exceed 5 days) of paid leave will be granted for Jury Duty

except in those jurisdictions that require more generous benefits. In those cases, the Company will follow the laws of the jurisdiction.

• If an employee is chosen to serve on a jury, they are entitled to their normal pay less any compensation they receive from the government.

• Employees should be scheduled for their normal hours. If the employee is unable to work their normal hours, Jury Duty hours may be used to make up hours up to their normal hours.

o For example: If the employee normally works 20 hours a week, and due to jury duty can only be scheduled for 8 hours that week, the employee would be paid for 12 hours of Jury Duty so their total hours for the week would be 20 hours.

• Checks received from the government may be endorsed over to Urban Outfitters, Inc., and sent to the Payroll Department, or copies of checks may be sent to Payroll and Payroll will deduct the amount from the employee’s pay for the week. If the employee does not use Jury Duty time, they may keep the government check.

Reporting Jury Duty

• The employee’s hours are entered using the pay code Jury Duty up to a maximum of 40 hours. • Salaried employees: enter 8 hours using the pay code Jury Duty. Refer to the “Improper

Deductions are Prohibited” section below for additional guidance. • Hourly employees: to the extent possible, hourly employees should be scheduled for their normal

hours. If Jury Duty hours are taken, enter the hours the employee was scheduled to work on that day, up to a maximum of 8 hours.

Improper Deductions are Prohibited: Exempt employees typically must receive their full salary for any week in which they perform any work, without regard to the number of days or hours worked. For example: if a manager is on Jury Duty for more than one week and they return to work part way through the next week, they receive full payment for the week they returned part way through. 11. Travel Time Pay There may be times when an hourly/non-exempt employee travels within the scope of their employment (for example, for new store openings, prototypes, work-throughs or similar assignments). This section outlines the Company’s policy on compensable travel time and the pay rules that apply to hourly/non-exempt employees when travelling. The Company adheres to federal and state requirements on compensation for travel time. As detailed below, hourly/non-exempt employees who travel within the scope of their employment may be eligible for compensation (referred to as “travel pay”) for time spent traveling beyond their regular commute,

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including travel to a different work location that is a further distance than the employee’s normal place of work, as well as travel at the request of the Company to undergo training. The employee may also be entitled to reimbursement for reasonable travel or training expenses incurred (for example, parking, cost of training materials). Please refer to the Travel Policy and Expense Report Procedures for more information on reimbursement for travel and other expenses.

Entitlement to travel pay depends on the kind of travel and whether the travel time takes place within normal work hours.

• For purposes of this policy, “normal work hours” are defined as an employee’s regularly scheduled work hours (for example, 7:00am to 4:00pm). This definition applies to normal workdays (Monday through Friday) and to weekends (Saturday and Sunday).

• Employees with variable work hours will have their normal work hours defined prior to travel based on a review of time records over the previous month. Partner with the HR Department.

Commuter Travel

• For any employee, time spent commuting from the employee’s home to the employee’s normal place of work and back is not considered compensable time, regardless of whether the employee reports to work at a fixed location or to various job sites.

• “Home” is considered any location of origin for the commute that is at the employee’s discretion. Single-Day Travel

• An employee who is required to travel for a one-day assignment to an alternate work location and returns home the same day will be paid for the time spent traveling to and from the alternative work location less the time the employee would normally spend commuting to and from their regular worksite.

• For instructions on reporting travel time, see the “Reporting Travel Time” section below. Multi-Day Travel

• Multi-day travel is work-related travel that requires at least one overnight stay away from the employee’s home.

• Travel away from home is considered hours worked (and therefore compensable) when: o the travel time takes place during the employee’s normal work hours, as defined above,

regardless of the day of the week, and o the employee is traveling by plane, train, bus or as a passenger in a car.

• Travel time spent driving an automobile (as the driver, not passenger) is treated as work hours, regardless of whether the travel takes place within normal work hours or outside normal work hours.

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• Time spent travelling from home to an airport or train station is NOT treated as hours worked and NOT compensable as travel pay.

o Time spent waiting at an airport terminal or train station until the employee arrives at their destination (e.g., the hotel or the store to which they are travelling) is compensable only if it occurs during the employee’s normal work hours.

• Travel to or from the airport from a work location, such as the employee’s home store or a different store, is compensable time if it occurs during the employee’s normal work hours.

• When an employee travels between time zones, the time zone associated with the point of departure is used to determine whether the travel falls within normal work hours.

• Travel time that occurs outside of the employee’s normal work hours is NOT considered work hours and therefore not compensable as travel pay.

• Calculation of travel time pay for international travel will be handled on a case-by-case basis. Partner with your Brand Operations team. Time spent travelling internationally will be paid at the minimum wage rate for the employee’s home store (or at the regular hourly rate if the employee’s home store is in California). Refer to the Reporting Travel Time section below.

Multi-Day Travel Example Type of Travel Normal Work Hours Travel Itinerary Amount of Travel Pay

Departing trip Traveling from Philadelphia to Miami

7:00am – 4:00pm Leaves from home and arrives at airport at 1:00pm Flight departs at 3:00pm Arrives at hotel in Miami at 6:00pm

3 hours of travel pay at minimum wage rate (Travel time started at 1:00pm, when arrived at airport, and ended at 4:00pm, when the employee’s normal work hours conclude)

Return trip Traveling from Miami to Philadelphia

7:00am – 4:00pm Leaves from hotel and arrives at airport at 9:00am Flight departs at 11:00am Arrives at Philadelphia airport at 1:30pm

4.5 hours of travel pay at minimum wage rate (Travel time started at 9:00am, when arrived at airport, and ended at 1:30pm, when arrived at home airport)

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Specific Travel Itineraries or Modes of Transportation • If an employee requests a specific travel itinerary or mode of transportation that is different from the

one authorized by the Company, only the estimated travel time associated with the authorized itinerary and mode of transportation will be eligible for compensation.

• For example: If an employee drives a car as a matter of personal preference when an authorized flight or other travel mode is available, and the travel time by car would exceed that of the flight, only the estimated travel time associated with the authorized mode of transportation will be compensated.

Work Performed While Traveling

• Any work that an employee performs while traveling must be counted as hours worked and the employee will be paid their regular hourly rate for such hours.

• Employees are responsible for accurately tracking and reporting regular hours worked during travel time in Dimensions.

Reporting Travel Time

• Travel time must be entered in Dimensions using the pay code “Travel”. o The travel time should be entered into Dimensions by the employee’s home store manager

on each day incurred to ensure the hours are applied to the current pay week. o Note: The employee traveling is still required to punch in at the destination location for their

scheduled work time. • Meal periods are NOT counted toward hours worked and must be deducted from the travel time. • Travel time that is considered hours worked is counted toward the employee’s total weekly hours for

overtime purposes. • Time spent traveling will be paid at the minimum wage rate for the employee’s home store.

o California employees only: Employees whose home store is in California will be paid at their regular hourly rate.

12. Lateness/Sick Reporting Every employee is required to report to work on time for every day that they are on the schedule.

• If an employee is going to be absent from work, they must contact a manager at least three hours before the shift is scheduled to begin or as soon as possible.

• If necessary, the manager should be called at home. • If an employee is going to be late, they must contact a manager at least one hour prior to the

beginning of their shift. • Excessive absenteeism or tardiness, failure to call in for a period of 3 or more days or failure to

provide proper notice and justification, may result in disciplinary action up to and including

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termination. • Please see your respective brand’s attendance policy for further documentation regarding lateness

and absenteeism.

13. Emergency Closing If a store needs to close early, delay opening, or remain closed on a day it is normally scheduled to be open due to severe weather conditions, power outage or emergencies of another nature, the following pay policies apply. State minimum hour laws supersede these pay policies when an employee is sent home in the middle of a scheduled shift for any other reason or when the minimum hour laws are more generous. Refer to the Payment for Minimum Hours Worked section below.

• The Store Brand Leader is responsible for ensuring that all scheduled employees are contacted at least one hour prior to their scheduled starting time when the store is closing early, opening late or remaining closed.

• Once the decision has been made to close early, open late or stay closed, the District Brand Leader must send an e-mail to the appropriate distribution list:

o [email protected] o [email protected] o [email protected] This distribution list includes Home Office employees in Store Operations, IT, POS,

Sales Audit and the Distribution Center. • If anticipated, state in the e-mail that shipment will not be received. • If closing due to a power outage, state in the e-mail whether the power outage is isolated to your

store or impacting the entire mall, block, etc. • Alert the same distribution list once the store reopens. • For guidance on handling emergency situations, refer to the Emergency Procedure and Safety

Reference Guide.

If the store opens as usual and closes early: • All hourly employees who arrive for work will be paid for actual hours worked for that day, or a

minimum of 4 hours, regardless of whether they are full-time or part-time. • Additional hours that need to be paid to the employee beyond the time they clock in and out (i.e., to

get the employee up to the 4-hour minimum) may be entered into Dimensions using the pay code Emergency Closing. o For example: An employee is scheduled 6 hours. The employee comes to work and works 2.2

hours before the store closes early. The employee will be paid 2.2 regular hours (for hours actually worked) and should be coded 1.8 hours as Emergency Closing pay (2.2 + 1.8 = 4.0

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hours). The employee is not paid for the remaining hours of their shift that were not worked. o An employee is scheduled 8 hours. The employee comes to work and works 5.08 hours before

the store closes. This employee is not paid any Emergency Closing pay. The employee’s actual hours worked satisfies the 4-hour minimum policy. Therefore, no additional pay is due.

• Any hourly employees who have not yet come to work must be notified by a manager as soon as the decision is made to close early. These employees will not be paid; however, they may attempt to make up these hours, to the extent possible, by scheduling hours to work later in the week. They may also choose to use a vacation day.

• Hourly employees who request to leave early due to severe weather conditions or an emergency will be paid only for actual hours worked.

If the store opens late:

• When the decision is made to delay an opening, the Store Brand Leader must attempt to contact all employees scheduled to open with the revised opening time.

• All hourly employees who arrive for work at the revised time will be paid for actual hours worked for that day, or a minimum of 4 hours, regardless of whether they are full-time or part-time.

• Employees whose scheduled shift begins after the revised opening time will be paid as usual. • In the event that an employee is not contacted by a manager and arrives at their normally scheduled

time, they should immediately call a manager at home to determine when the store will open. • If the store is opening within 2 hours of the call, the employee should wait for a manager and will be

paid for the two hours they waited in addition to the hours they work that day, at a minimum of 4 hours. (The employee may return home if it is close by and come back to the store at the time designated by the manager.)

• If the store is opening later than 2 hours from the time of the call, the employee should go home and return for work at the time designated by the manager. They will be paid for 2 hours in addition to the hours they actually work that day, at a minimum of 4 hours.

• If the store ends up remaining closed, the employee would be paid according to guidelines outlined in the first scenario.

If the store remains closed: If the decision is made to keep the store closed, all hourly employees are to use the day as their day off for that week. Every effort should be made by the manager to schedule the hours lost later in the week, giving available hours to full-time employees first. Employees may also use vacation days. Note: Any exceptions to these pay procedures must be approved by the Regional Brand Director or Director of Retail.

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14. Payment for Minimum Hours Worked Stores in the following states are required to pay scheduled employees for minimum hours worked. If for any reason an employee is sent home in the middle of a scheduled shift other than emergency closing as noted above, the following chart specifies regulations regarding payment for minimum hours worked.

• If your state is not listed in the below chart and the labor law posters in your store do not state otherwise, then there are no regulations concerning minimum hours worked.

• Any questions regarding calculating payment may be directed to Store Operations.

State Minimum Hour Requirement

California If the employee is not put to work or works with less than half the usual or scheduled day’s work, the employee must be paid for half the usual or scheduled day’s work, not less than 2 hours and not more than 4 hours.

Connecticut Must be paid for at least 4 hours when the employee reports for work and no work is provided by the employer or the employee does not work at least 4 hours.

Colorado, Illinois, Kansas, Minnesota, Wisconsin

Must pay the employee for the time they wait on the premises when no work is provided by the employer.

Massachusetts & Rhode Island

If no work is provided, employee must be paid for at least 3 hours.

New Jersey Must be paid for at least 1 hour.

District of Columbia and New York Must be paid for 4 hours of work or the number that was scheduled, whichever is less.

Minimum Hours requirements for California, Connecticut, New Jersey, New York, District of Columbia, Massachusetts, and Rhode Island ONLY are configured within Dimensions to trigger exceptions which will populate on the timecard. Managers are required to manage these exceptions daily to ensure the appropriate hours are applied to the employee’s timecard. If the employee was sent home due to an emergency closing, managers may need to manually add hours (up to 4 hours) using the Emergency Closing pay code. Please refer to the Dimensions Manager’s Guide and Dimensions Manager’s Basic Scheduling Guide (BHLDN & Terrain) for further documentation on Minimum Hours Worked. All other scenarios must be entered manually by the manager on duty for each employee, per their state’s requirements. 15. Unscheduled Shifts Urban Outfitters, Inc. prohibits the use of on-call shifts in all North American stores. When a manager determines that unanticipated business needs require hourly employees to work additional unscheduled shifts,

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managers should utilize a voluntary contact list to request that available employees take the additional shift. Participation in the contact list shall be completely voluntary and employees may not be treated adversely for declining additional shifts.

If a manager determines that unanticipated business needs require that hourly employees should be sent home early or that a shift should be canceled, managers should communicate such decisions as soon as practical and must also comply with any applicable Minimum Hours Worked requirements (see Section 13 of this policy). Schedules should be posted at least two weeks in advance of the schedule week. Managers are not permitted to intentionally overschedule and eliminate shifts to artificially create the equivalent of an on-call shift.

16. California Split Shift Pay In California, if an employee works a split shift, the employee may be entitled to 1 hour of additional pay at minimum wage. A split shift means a work schedule that is interrupted by unpaid, non-working periods established by the employer, other than a bona fide rest or meal period.

An employee may not be entitled to split shift pay if their hourly wage exceeds the minimum wage. To determine if split shift pay is due, multiply the difference in rate (between the hourly wage and the minimum wage) by the hours worked that day. If the product of those numbers exceeds the split shift pay (one hour at minimum wage), the split shift premium is offset and not owed. Example #1: Where the Premium Is Owed An employee in California who makes $11.00/hour (the 2018 minimum wage for large employers in California) works the first shift from 9:00am to 1:00pm, and works a second shift later that day from 3:00pm to 7:00pm for a total of 8 hours.

• $11.00 x 8 hours = $88.00 (daily wage) • $88.00 + $11.00 (the premium pay) = $99.00 • The total due for that workday is $99.00 ($11.00 x 8 hours + $11.00 premium)

Example #2: Where the Premium Is Not Owed An employee in California who makes $13.00/hour works the first shift from 9:00am to 1:00pm, and works a second shift later that day from 3:00pm to 7:00pm for a total of 8 hours.

• $13.00 x 8 hours = $104.00 (daily wage) • $13.00 - $11.00 = $2.00 (difference between hourly and minimum wage) • $2.00 x 8 hours = $16.00 • Split shift premium is not owed because $16.00 is greater than the split shift premium of $11.00

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• The total due for that workday is $104.00

Split shift premiums are not automatically paid in Dimensions. When closing out the payroll for the week, managers must manually add any premiums using the Split Shift pay code in Dimensions.

17. New York Spread Shift and Split Shift Penalty In New York, if an employee works a split shift (a schedule of daily hours in which the working hours are not consecutive; no meal period of one hour or less shall be considered an interruption of consecutive hours) or if there is a spread of hours (the time between the first punch in and the last punch out for the day) that exceeds 10 hours, then the employee may be entitled to 1 hour of additional pay at minimum wage.

Example #1: Where the Premium Is Owed An employee in New York City who makes $14.00/hour works a 10-hour shift. Effective 12/31/2017, the minimum wage for large employers in New York City is $13.00.

• $14.00 x 10 hours = $140.00 (daily wage) • $14.00 - $13.00 = $1.00 (difference between hourly and minimum wage) • $1.00 x 10 = $10.00 • A spread shift premium is owed because $10.00 is less than the spread shift premium of $13.00 • $140.00 + $13.00 (the premium pay) = $153.00 The total due for that workday is $153.00 ($14.00 x 10 hours + $13.00 premium)

Example #2: Where the Premium Is Not Owed An employee in New York City who makes $15.00/hour works a 10-hour shift. Effective 12/31/2017, the minimum wage for large employers in New York City is $13.00.

• $15.00 x 10 = $150 (daily wage) • $15.00 - $13.00 = $2.00 (difference between hourly and minimum wage) • $2.00 x 10 hours = $20.00 • A spread shift premium is not owed because $20.00 is greater than the spread shift premium of

$13.00 • The total due for the workday is $150.00

Spread shift and split shift penalties are not automatically paid in Dimensions. However, Dimensions will provide a “long shift warning” to notify a manager that a spread shift penalty may have been triggered based on an employee’s punches. When closing out the payroll for the week, managers must manually add any penalties using the Split Shift pay code in Dimensions.

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18. Dimensions Mobile App Urban Outfitters, Inc. provides all stores with access to the Dimensions Mobile App, which is downloaded to store mobile devices. This app is also available for downloading to personal mobile devices for all active store employees. Downloading and the use of this app on a personal mobile device is not a requirement of working at Urban Outfitters, Inc. and all functions available on the app are available on the store mobile devices and through other traditional channels (e.g., schedules are still posted in the store, paid time off balances can still be viewed on the paycheck). Hourly management are not permitted to complete any management functions on the Dimensions app on store or personal devices outside of a scheduled shift. Listed below are general employee and management features available on the Dimensions Mobile App:

Employee App Features

• View: o Timecards o Current schedule o PTO balances

• Submit requests for: o Availability change (temporary) o Shift swap o Time off o Coverage o Open Shift/Unassigned Hours o Review and sign off on timecards

Management App Features

• In addition to the Employee App Features, managers can: o Manage timecards and exceptions o Manage request (shift swap, coverage, availability, time off, and open shift) o Manage schedules (tablet only) o View reporting

For more information, please see the Dimensions Employee Guide. Vacation and Sick Leave Refer to the Vacation and Sick Leave Policy for your location.