Benefits Handbook Links - Updated February 2023

Tuition Reimbursement Program

Tuition Reimbursement Venable recognizes the importance of an educational assistance program that assists employees in their pursuit of higher education and professional development. We have established a program to provide financial assistance to those eligible employees wishing to further their education through course work at an accredited educational institution. Under the tuition reimbursement program, tuition costs for both job-related and non-job-related courses may be covered up to $5,250 per calendar year, subject to the following limitations: • 100 percent of tuition costs reimbursed for job-related courses. • 50 percent of tuition costs reimbursed for business related courses not directly related to the function of your position. [will “related” link somewhere?] Who is Eligible? Eligibility for the tuition reimbursement program is limited to full-time employees who have successfully completed their introductory period. Only courses that begin after the employee has successfully completed the introductory

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period are considered eligible. Whether course work qualifies for educational assistance will be considered on a case-by-case basis at the sole discretion of Venable. Eligible Expenses • Job-related or non-job-related courses taken for credit at an accredited college or university • Tuition and per unit credit fees • Required registration fees (school fee schedule discloses required fees)

Ineligible Expenses: • Non-job-related courses that do not fulfill job-related degree program requirements • Parking fees • Late registration fees

• College level examination test • Books or other course materials • Admission tests • Any additional fees deemed ineligible by the Benefits Administrator

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How the Benefit Works You are eligible to participate in the tuition reimbursement program after you have completed your introductory period with Venable. You can apply for assistance only for courses that begin after your introductory period has ended. You may request reimbursement upon successful completion of the course with a grade of “C” or better or “P” (if pass/fail). You will receive reimbursement for the cost of tuition specific to your course work. Approvals for tuition reimbursement will be limited to $5,250 per calendar year per employee based on the year the reimbursement is paid. Your completed application must be submitted by December 15 if you are requesting reimbursement in the same calendar year in which the course ends. Application Process The tuition reimbursement application is located on intersect. Prior to the start of your course, you must obtain approval from your supervisor. Complete section one of the application and obtain your supervisor’s signature. Once you have your supervisor’s approval, forward the completed application to benefits@venable.com along with a course description and cost per credit summary. Please retain a copy for your personal records of all materials submitted and communication received. The Benefits Administrator will confirm your approval to take the course and the amount you can receive for reimbursement.

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Upon completion of the course, complete section three of the application to indicate which courses you have completed, the grade received, and the amount paid. You must submit proof of your passing grade (C or better, as applicable) and proof of payment within 60 days of course completion. Your completed application must be submitted by December 15 if you are requesting reimbursement in the same calendar year in which the course ends. Reimbursement applies to tuition costs only and will be made after satisfactory completion of the course (grade C or better, as applicable), once you have presented your tuition receipt and grade record. The amount of reimbursement you are eligible to receive will be reduced by:

• any governmental assistance or other scholarship you receive • any fees included in the cost that are not sole tuition costs • the cost of books or other course materials • any amounts previously reimbursed in the current year up to the annual maximum

Tuition reimbursement payments, while subject to change, are currently a non-taxable benefit. Reimbursement will not be made if your employment ends prior to your submission of properly reimbursement paperwork. Approvals for tuition reimbursement will be limited to $5,250 per calendar year per employee based on the year the class began.

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Supporting Documentation Required The following documentation is required to receive tuition reimbursement: • Tuition reimbursement application with supervisor approval • Statement of account form the institution showing tuition, registration fees and payments that have been made • Cost per credit • Final Grades Payment of Tuition Reimbursement Upon receipt of your final grades, the Benefits Team will email you that your request is approved. You will need to process your request for reimbursement in ChromeRiver and attach your completed application, proof of payment, and final grade. Once the request is approved, you will receive reimbursement via direct deposit within 3-5 business days. Termination of Employment If you voluntarily leave the Firm within 12 months of receipt of tuition reimbursement from the Firm, pursuant to the tuition assistance/reimbursement policy, you agree to reimburse the Firm in full for any tuition

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assistance/reimbursement paid by the Firm within those 12 months.

Funding for this program will be reviewed by firm management on an annual basis. Click here for the Tuition Reimbursement Form.

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Professional Development

Professional Development Training : In addition to tuition payments and examination fees, the Firm may also pay the cost of continuing professional education. To qualify, the course/seminar, etc. needs to be related to your position with the Firm, and approval by your supervisor is required. Generally, payment will be made as a reimbursement following completion of the course. Advance payment may be requested if you were asked by your supervisor to take the course. When you attend an approved training program or seminar outside of work, you may be reimbursed for certain expenses incurred to attend the program including examination fees for job-related professional certification designations. Reimbursable expenses for approved outside programs include travel (mileage at the Firm’s current established rate, parking, tolls, train fare, airfare and taxi, Uber or Lyft fare), actual expenditures for meals up to $50 per day when traveling to non-local seminars and the cost of overnight accommodations up to $200 per night, when

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required. Lunch will be covered at $15 per day, when attending a local seminar. Travel arrangements, when necessary, should be made through Venable’s travel agency. Receipts need to be provided in order to receive reimbursement for eligible expenses. Expenses must be entered into Chrome River immediately after the expense is incurred, and no later than 30 days beyond when the expense is incurred. Failure to submit expenses within that time frame may result in progressive discipline. Accounting processes expense reimbursement requests twice a week through direct deposit once requisite approvals are obtained through the automated workflow.

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Time Off to Vote

California If you do not have sufficient time outside of working hours to vote in a statewide election, you may use up to two hours of your accrued but unused sick or PTO leave to vote. The time off should be taken at the beginning or end of the regular working shift, whichever allows the most free time for voting and the least time off from working, unless otherwise mutually agreed upon. If you, at least three working days before the election, have reason to know that you will require such time off, you should notify your supervisor at least two working days in advance to arrange a voting time, if time off is needed to vote.

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Chicago

You may take up to two hours’ paid time off in order to vote, unless the polls are open two hours before or after your regular work hours. If you wish to take voting leave, you must request it prior to election day. The Firm may specify the hours when you may be absent. DC You may take up to two hours’ paid time off in order to vote: • in an election held in the District if you are eligible to vote in the District, or • in an election held in the jurisdiction in which you are eligible to vote (e.g., Maryland or Virginia). If you wish to take voting leave, you must request it at least two days in advance of the leave and specify the hours during which you plan to take paid leave to vote on Election Day or during the early voting period. Delaware If you have PTO accrued and available for use and are not in a critical need position, you will not be deprived of employment, nor threatened or coerced with respect thereto, because you are serving as an election officer on election day.

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Maryland If you do not have at least two consecutive hours off from work while the polls are open, you may take up to two hours of paid leave to vote. You must use your available accrued unused PTO first. New York You may request up to two hours of your accrued but unused PTO leave to vote, if you do not have four consecutive hours to vote either at the beginning or the end of your regular workday. You should notify your supervisor no less than two working days prior to the day of the election, but not more than 10 working days. Virginia Employees who serve as an election officer are eligible for unpaid time off if requested with reasonable notice.

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Leave of Absence

Medical (Non-FMLA) Leave of Absence There may be a time when you need to request a medical leave of absence (MLOA) but are not yet eligible for Family and Medical Leave (FMLA) or you may have exhausted Family and Medical Leave. Depending upon all of the circumstances, including our business needs and your ability to substantiate through physician documentation, leaves of absence may be granted. Venable complies with the provisions of the Pregnancy Discrimination Act (PDA), Americans with Disabilities Act (ADA), and the Americans with Disabilities Act Amendments Act (ADAAA). For more information regarding a medical leave of absence, including return to work and insurance plans, visit the complete policy below.

A leave of absence under this policy should be requested when:

• You need to request a non-FLMA medical leave of absence (MLOA) for yourself.

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Note: You may also be eligible to receive a disability benefit. Please refer to the full short-term disability policy here for further disability information. Your leave of absence will begin on the first day you cannot work for a reason that qualifies under Venable’s leave policies exclusive of PTO. You are required to use all of your available accrued leave (sick and PTO) prior to going on unpaid status. Allowances/Accrual. PTO and sick leave do not accrue during the period of an approved unpaid or paid MLOA. During the period of an approved unpaid or paid MLOA, you will not be paid for any Venable holidays and you will not be entitled to paid leave for jury duty or bereavement. PTO and sick leave will be accrued as of the last day worked. If you are on an approved MLOA on January 1 of any year, you will not be credited with your PTO, or sick leave for that year until you return to work on a regular basis. Disability. Please note that eligibility for or receipt of short- or long-term disability benefits does not automatically entitle you to be granted a leave of absence. For additional information, you may refer to the Short- and Long- Term Disability provisions of this handbook. Scheduling Leave. Please inform your supervisor of the need for leave and submit an application to the Benefits Department at benefits@venable.com. This request should be submitted as soon as you have reason to believe that you will need to be away from work. An approved LOA will not be extended beyond the dates of the initial request without further written approval.

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For an LOA not approved/paid under our short-term disability plan, you must use your accrued unused PTO and/or sick leave. Return to Work. In accordance with applicable law, Venable will require written documentation from your physician clearly stating that you are released to return to work and can safely perform your duties, with or without reasonable accommodation, or what restrictions, if any, you have and when the restrictions will be lifted. If you are granted a leave of absence and are able to return to work at the time specified in the leave approval, we will make an effort to place you in a position for which you are qualified, in Venable’s judgment, and one that is as similar in content and compensation as possible to the position you held before the leave began. However, because business needs change, we are not able to guarantee that a position with Venable will be available to you when you are scheduled to return. Decisions on whether to offer you a position upon your return from a leave of absence and which position to offer are solely within Venable’s discretion. Employees who are granted leave under the Family and Medical Leave Act should refer to the “Effect on Benefits and Employment” section of our Family and Medical Leave policy. Employees who are granted leave under USERRA should refer to the Military Leave policy for information regarding their reemployment rights. Subject to the requirements of applicable law, any Firm Personnel on an approved leave of absence (medical, personal, or otherwise) will terminate employment from the Firm on the earliest of the following:

• On the date the person resigns from the Firm;

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• On the date the person accepts or begins employment outside the Firm, in the Firm’s discretion; • 30 days after the person’s doctor releases him/her to return to work (with or without reasonable accommodation), but the person does not return within that 30-day period; • After 12 months of leave within a consecutive 18-month period; • Immediately following a failure to return from an approved personal leave of absence. The term “Firm Personnel” shall mean each person employed by Venable in any capacity, including legal, professional staff or other, excluding Equity Partner. The Firm reserves the right and discretion to administer and interpret this policy and to determine all questions regarding its applicability in any circumstance. This policy does not modify the Firm’s non-medical leave of absence policy. Insurance. If you are on a leave of absence and are receiving income benefits from Venable, coverage under Venable’s insurance plans will continue at no added expense to you. Income benefits include paid sick and PTO leave, as well as short-term disability benefits. If your income benefits cease, please contact our Benefits Department at benefits@venable.com to coordinate health benefit premium payments. Failure to pay monthly health benefit premiums may result in termination of benefits coverage.

Length of Service. A leave of absence will not affect your length of service with Venable.

Click here for the Medical (Non-FMLA) Process Flow chart for additional information.

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Non-Medical Leave of Absence (NMLOA) On occasion, employees may be unable to work for an extended period of time for such reasons as personal, related family concerns (which may not fall under FMLA coverage) or to pursue formal education. Depending upon all of the circumstances, including our business needs, your job performance, length of service, and the reason for needing the time off, an unpaid non-medical leave of absence of periods of two (2) weeks to six (6) months may be granted, at Venable’s discretion to employees who have satisfied the 90-day introductory period. Venable prohibits employees from engaging in other work, as either an employee or an independent contractor, while on NMLOA. For a leave of absence under the Family and Medical Leave Act, please refer to the Family and Medical Leave section of this handbook. For a leave of absence in order to perform qualifying military service under the Uniformed Services Employment and Reemployment Rights Act (USERRA), please refer to the Military Leave policy.

A leave of absence under this policy should be requested when:

• You need to request a personal leave of absence (PLOA) for personal or related family concerns. • You need to request an educational leave of absence (ELOA) to pursue a formal education program. Requests for educational leave must be approved prior to enrollment in a course of study.

Eligibility. Consideration will be given to those requests made by employees:

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• Who have successfully completed their 90-day introductory period of employment;

• Who have exhausted or will exhaust all of their available accrued but unused PTO and sick leave.

Allowances/Accrual. PTO and sick leave do not accrue during the period of an approved unpaid or paid LOA. During the period of an approved unpaid or paid LOA, you will not be paid for any Venable holidays and you will not be entitled to paid leave for jury duty or bereavement. PTO and sick leave will be accrued as of the last day worked. If you are on an approved LOA on January 1 of any year, you will not be credited with your PTO, or sick leave for that year until you return to work on a regular basis. Scheduling Leave. Please inform your supervisor of the need for leave and submit an application to the Benefits Department at benefits@venable.com. This request should be submitted as soon as you have reason to believe that you will need to be away from work. An approved LOA will not be extended beyond the dates of the initial request without further written approval. Return to Work. If you are granted a leave of absence and are able to return to work at the time specified in the leave approval, we will make an effort to place you in a position for which you are qualified, in Venable’s judgment, and one that is as similar in content and compensation as possible to the position you held before the leave began. However, because business needs change, we are not able to guarantee that a position with Venable will be available to you when you are scheduled to return. Decisions on whether to offer you a position upon your return

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from a leave of absence and which position to offer are solely within Venable’s discretion. Employees who are granted leave under the Family and Medical Leave Act should refer to the “Effect on Benefits and Employment” section of our Family and Medical Leave policy. Employees who are granted leave under USERRA should refer to the Military Leave policy for information regarding their reemployment rights. Employees who accept other employment, do not return to work on the first regularly scheduled day of work following the expiration of the leave, apply for unemployment insurance benefits (UIB), or fail to accept an offer of reinstatement to a position selected by Venable will be deemed to have voluntarily resigned without notice as of the expiration of the approved leave period or the date of acceptance of other employment, whichever occurs first. Insurance. If you are on a leave of absence and are receiving income benefits from Venable, coverage under Venable’s insurance plans will continue at no added expense to you. Income benefits include paid sick and PTO leave, as well as short-term disability benefits. If your income benefits cease, please contact our Benefits Department at benefits@venable.com to coordinate health benefit premium payments. Failure to pay monthly health benefit premiums may result in termination of benefits coverage.

Length of Service. A leave of absence will not affect your length of service with Venable.

Click here for the link to the Process Flow chart for additional information.

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Family and Medical Leave Act

FAMILY AND MEDICAL LEAVE ACT POLICY Venable will provide Family and Medical Leave to its eligible employees. The Firm posts the mandatory FMLA Notice required by the U.S. Department of Labor (DOL) on Employee Rights and Responsibilities under the Family and Medical Leave Act in both the kitchen/break area and on the Firm intranet. The function of this policy is to provide you with a general description of your FMLA rights. In the event of any conflict between this policy and the applicable law, you will be afforded all rights required by law. If you have any questions, concerns, or disputes with this policy, please contact the Manager, Benefits & Wellness at benefits@venable.com.

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A. General Provisions

Under this policy, Venable will grant up to 12 work weeks (or up to 26 work weeks of military caregiver leave to care for a covered service member with a serious injury or illness) during a 12-month period to eligible employees. The leave may be paid, unpaid or a combination of paid and unpaid leave, depending on the circumstances of the leave and as specified in this policy. B. Eligibility To qualify to take family or medical leave under this policy, you must meet all of the following criteria: 1. You must have worked for the Firm for 12 months or 52 weeks. The 12 months or 52 weeks need not have been consecutive. Separate periods of employment will be counted, provided that the employee has worked a total of 12 months within the last seven years since the most recent date of hire. Separate periods of employment will be counted if the break in service beyond seven years is due to National Guard or Reserve military service obligations or when there is a written agreement, including a collective bargaining agreement, stating Venable’s intention to rehire you after the service break. For eligibility purposes, you will be considered to have been employed for an entire week even if you were on the payroll for only part of a week or if you are on leave during the week.

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2. You must have worked at least 1,250 hours during the 12-month period immediately preceding the commencement of the leave. The 1,250 hours do not include time spent on paid or unpaid leave. 3. You must work in a worksite where 50 or more employees are employed by the Firm within 75 miles of that office or worksite. C. Type of Leave Covered To qualify as FMLA leave under this policy, you must be taking leave for one of the following reasons: 1. The birth of a child and in order to care for that child. 2. The placement of a child for adoption or foster care and to care for the newly placed child. 3. To care for a spouse, child or parent with a serious health condition (described below). 4. The serious health condition (described below) of the employee. A serious health condition is defined as a condition that requires inpatient care at a hospital, hospice or residential medical care facility, including any period of incapacity or any subsequent treatment in connection with such inpatient care or a condition that requires continuing care by a licensed health care provider. This policy covers illnesses of a serious and long-term nature, resulting in recurring or lengthy absences. Generally, a chronic or long-term health condition that would result in a period of more than three consecutive calendar days

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of incapacity with the first visit to the health care provider within seven days of the onset of the incapacity and a second visit within 30 days of the incapacity would be considered a serious health condition. For chronic conditions requiring periodic health care visits for treatment, such visits must take place at least twice a year. A serious health condition may also include a period of incapacity due to pregnancy or for prenatal care, certain chronic conditions, long-term conditions for which treatment may not be effective when the employee is under the supervision of a doctor, and certain conditions requiring multiple periodic treatments which would likely result in incapacity in the absence of medical treatment. Employees with questions about what illnesses are covered under this FMLA policy or under the Firm's sick leave policy are encouraged to consult with the Manager, Benefits & Wellness at benefits@venable.com. If you take paid sick leave for a condition that progresses into a serious health condition and you request unpaid leave as provided under this policy, the Firm may designate all or some portion of your related leave taken as leave under this policy, to the extent that the earlier leave meets the necessary qualifications. 5. Qualifying exigency leave for families of members of the National Guard or Reserves or of a regular component of the Armed Forces when the covered military member is on covered active duty or called to covered active duty.

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An employee whose spouse, son, daughter or parent either has been notified of an impending call or order to covered active military duty or who is already on covered active duty may take up to 12 work weeks of leave for reasons related to or affected by the family member’s call-up or service.

The qualifying exigency must be one of the following: a) short-notice deployment b) military events and activities c) certain child care and related activities

d) care of military member’s parent e) financial and legal arrangements f) counseling g) temporary rest and recuperation during deployment h) certain post-deployment activities, and i) Additional activities that arise out of active duty, provided that Venable and the employee agree, including agreement on timing and duration of the leave. The leave may commence as soon as the individual receives the call-up notice. (Parent, spouse, son or daughter for this type of FMLA leave is defined the same as for child for other types of FMLA leave except that the son or daughter does not have to be a minor.) This type of leave would be counted toward the employee’s 12-work week maximum of FMLA leave in a 12-month period.

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6. Military caregiver leave (also known as covered service member leave) to care for an injured or ill service member or veteran. An employee whose son, daughter, spouse, parent or next of kin is a covered service member may take up to 26 work weeks in a single 12-month period to take care of leave to care for that service member. Eligible employees are entitled to FMLA leave to care for a current member of the Armed Forces, including a member of the National Guard or Reserves, or a member of the Armed Forces, the National Guard or Reserves who is on the temporary disability retired list, who has a serious injury or illness incurred in the line of duty on active duty for which he or she is undergoing medical treatment, recuperation, or therapy; or otherwise in outpatient status; or otherwise on the temporary disability retired list. Eligible employees may not take leave under this provision to care for former members of the Armed Forces, former members of the National Guard and Reserves, and members on the permanent disability retired list. D. Amount of Leave As an eligible employee, you can take up to 12 work weeks for the FMLA circumstances (1) through (5) above during any 12-month period. The Firm will measure the 12-month period as a rolling 12-month period measured backward from the date you use any leave under this policy. Each time you take leave, the Firm will compute the amount of leave you have taken under this policy in the last 12 months and subtract it from the 12 weeks of available leave, and the balance remaining is the amount you are entitled to take at that time.

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As an eligible employee, you can take up to 26 work weeks for the FMLA circumstance (6) above (military caregiver leave) during a single 12-month period. For this military caregiver leave, the Firm will measure the 12-month period as a rolling 12-month period measured forward. FMLA leave already taken for other FMLA circumstances will be deducted from the total of 26 weeks available. If eligible spouses both work for the Firm and each wishes to take leave for the birth of a child, adoption or placement of a child in foster care, or to care for a parent (but not a parent "in-law") with a serious health condition, the spouses may only take a combined total of 12 weeks of leave. If eligible spouse both work for the Firm and each wishes to take leave to care for a covered injured or ill service member, the spouses may only take a combined total of 26 weeks of leave. E. Employee Status and Benefits During Leave While you are on leave, the Firm will continue your health coverage during the leave period at the same level and under the same conditions as if you had continued to work. You will, however, continue to pay your portion of the premiums for coverage, as well as any contributions to the medical flexible spending account, should you wish to keep such coverage in effect. Coverage under Venable’s life and long-term disability policies will be continued in accordance with the provisions set forth in our general Leave of Absence policy. If the payment is more than 30 days late, your health care coverage may be cancelled for the duration of the leave. If the date of your scheduled annual performance review occurs during a period of approved FMLA leave, the performance evaluation will be completed when you return to work. Depending on the circumstances, Venable

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may prohibit employees from engaging in other work, as either an employee or an independent contractor, while on FMLA leave. Should you fail to return to work after the expiration of leave, you may, depending on the circumstances, be required to reimburse the Firm the amount it paid for your health insurance premium during the leave period. F. Employee Status After Leave An employee who takes leave under this policy may be asked to provide a fitness for duty (FFD) clearance from the health care provider. This requirement will be included in the Venable’s response to the FMLA request. Generally, an employee who takes FMLA leave will be able to return to the same position or a position with equivalent status, pay, benefits and other employment terms. The Firm may choose to exempt certain highly paid salaried employees from this requirement and not return them to the same or similar position. G. Use of Paid and Unpaid Leave An employee who is taking FMLA leave because of their own serious health condition or the serious health condition of a family member must use all accrued but unused paid PTO or sick leave prior to being eligible for unpaid leave. Sick leave may be run concurrently with FMLA leave if the reason for the FMLA leave is covered by the established sick leave policy.

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Disability leave for the birth of the child and for your own serious health condition, including workers' compensation leave (to the extent that it qualifies), will be designated as FMLA leave and will run concurrently with FMLA. For example, the Firm provides the following paid parental benefits for non-legal staff members. (Attorneys should refer to the Operations Manual for details on this policy): o Paid Maternity Leave: Four weeks of leave paid. (Issued at the conclusion of any short-term disability benefits paid.)

o Paid Paternity Leave: Four weeks of leave paid o Paid Adoption Leave: Four weeks of leave paid .

The paid leave is compensated at the following levels: o Staff members with less than five years of service are eligible to receive an employee benefit of 70% of your weekly earnings. o Staff members with five years or more of service are eligible to receive an employee benefit of 90% of your weekly earnings. The above paid leave weeks will be designated as FMLA leave and counted toward your 12-week entitlement. You may then be required to substitute accrued but unused paid leave as appropriate before being eligible for unpaid leave for what remains of the 12-week entitlement.

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If you are using military FMLA leave for a qualifying exigency, you must use all accrued but unused paid PTO and sick leave prior to being eligible for unpaid leave. If you are using FMLA military caregiver leave, you must also use all accrued but unused paid PTO and sick leave (as long as the reason for the absence is covered by the Firm’s sick leave policy) prior to being eligible for unpaid leave. If a Venable observed holiday occurs while you are on unpaid consecutive FMLA leave, you will not receive holiday pay. You must use PTO or sick leave if available, or take unpaid time off. In DC and CA, you may elect to take unpaid time off. While you are on consecutive FMLA leave, you will not receive jury duty pay if you appear for jury duty or are required to appear in court as a witness. You will be paid at the appropriate percentage level per the short-term disability plan, if applicable. While you are on consecutive FMLA leave, you will not receive bereavement leave pay. You will be paid at the appropriate percentage level per the short-term disability plan, if applicable. H. Intermittent Leave or a Reduced Work Schedule The employee may take FMLA leave in 12 consecutive weeks, may use the leave intermittently (take a day periodically when needed over the year) or, under certain circumstances, may use the leave to reduce the workweek or workday, resulting in a reduced hour schedule. In all cases, the leave may not exceed a total of 12 workweeks (or 26 workweeks to care for an injured or ill service member over a 12-month period).

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The Firm may temporarily transfer you to an available alternative position with equivalent pay and benefits if the alternative position would better accommodate the intermittent or reduced schedule, such as in instances when leave for you or your family member is foreseeable or for planned medical treatment, including recovery from a serious health condition or to care for a child after birth, or placement for adoption or foster care. Leave for birth, adoption or foster care of a child must be taken within one year of the birth or placement of the child and cannot be taken intermittently (it must be taken as a continuous block of leave). If you are taking leave for a serious health condition or because of the serious health condition of a family member, you should try to reach agreement with the Firm before taking intermittent leave or working a reduced hour schedule. If this is not possible, then you must provide medical certification confirming that the use of the leave is medically necessary. I. Use of Paid and Unpaid Leave An employee who is taking FMLA leave intermittently because of their own serious health condition or the serious health condition of a family member intermittently must use all accrued but unused PTO or sick leave prior to being eligible for unpaid leave. Sick leave may be run concurrently with FMLA leave if the reason for the FMLA leave is covered by the established sick leave policy.

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J. Certification for the Employee’s Serious Health Condition The Firm will require certification for the employee’s serious health condition. You must respond to such a request within 15 days of the request or provide a reasonable explanation for the delay. Failure to provide certification may result in a denial of continuation of leave. Medical certification will be provided using the Department of Labor Certification of Health Care Provider for Employee’s Serious Health Condition available here. The Firm, through a health care professional, an HR professional or management official, may directly contact your health care provider for authentication or clarification purposes. The Firm will not use your direct supervisor for this contact. Before the Firm makes this direct contact with the health care provider, you will be a given an opportunity to resolve any deficiencies in the medical certification. In compliance with HIPAA Medical Privacy Rules, the Firm will obtain your permission for clarification of individually identifiable health information. The Firm has the right to ask for a second opinion if it has reason to doubt the certification. If the Firm requests a second opinion, the Firm will pay for you to get a certification from a second doctor, which the Firm will select. The Firm may deny FMLA leave in the event you refuse to release relevant medical records to the health care provider designated to provide a second or third opinion. If necessary to resolve a conflict between the original certification and the second opinion, the Firm will require the opinion of a third doctor. The Firm and the employee will mutually select the third doctor, and the Firm will pay for the opinion. This third opinion will be considered final. You will be provisionally entitled to leave and benefits under the FMLA pending the second and/or third opinion.

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If the second and/or third opinion is denied, any PTO or sick leave previously paid to you during your leave will not be returned. K. Certification for the Family Member’s Serious Health Condition The Firm will require certification for the family member’s serious health condition. You must respond to such a request within 15 days of the request or provide a reasonable explanation for the delay. Failure to provide certification may result in a denial of continuation of leave. Medical certification will be provided using the Department of Labor Certification of Health Care Provider for Family Member’s Serious Health Condition available here. The Firm, through a health care professional, an HR professional or management official, may directly contact your family member’s health care provider for verification or clarification purposes. The Firm will not use your direct supervisor for this contact. Before the Firm makes this direct contact with the health care provider, you will be a given an opportunity to resolve any deficiencies in the medical certification. In compliance with HIPAA Medical Privacy Rules, the Firm will obtain your family member’s permission for clarification of individually identifiable health information. The Firm has the right to ask for a second opinion if it has reason to doubt the certification. If the Firm requests a second opinion, the Firm will pay for your family member to get a certification from a second doctor, which the Firm will select. The Firm may deny FMLA leave in the event your family member refuses to release relevant

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medical records to the health care provider designated to provide a second or third opinion. If necessary to resolve a conflict between the original certification and the second opinion, the Firm will require the opinion of a third doctor. The Firm and the employee will mutually select the third doctor, and the Firm will pay for the opinion. This third opinion will be considered final. You will be provisionally entitled to leave and benefits under the FMLA pending the second and/or third opinion. If the second and/or third opinion is denied, any PTO or sick leave previously paid to you during your leave will not be returned. L. Certification of Qualifying Exigency Military Family Leave The Firm will require certification of the qualifying exigency for military family leave. You must respond to such a request within 15 days of the request or provide a reasonable explanation for the delay. Failure to provide certification may result in a denial of continuation of leave. This certification will be provided using the Department of Labor Certification of Qualifying Exigency for Military Family Leave available here.

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M. Certification for Serious Injury or Illness of Covered Service member for Military Family Leave

The Firm will require certification for the serious injury or illness of the covered service member. You must respond to such a request within 15 days of the request or provide a reasonable explanation for the delay. Failure to provide certification may result in a denial of continuation of leave. This certification will be provided using the Department of Labor Certification for Serious Injury or Illness of Covered Service Member available here. N. Recertification The Firm may request recertification for your serious health condition or that of your family member at its discretion if the Firm receives information casting doubt on the reason given for the absence, or if you seek an extension of your leave. The Firm may provide your health care provider with your attendance records and ask whether your usage of leave is consistent with your serious health condition. O. Requesting FMLA Leave All employees requesting FMLA leave must complete an application and follow the process outlined in the Employee Overview of FMLA Process.

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When the need for the leave is foreseeable, you must provide the Firm with at least 30 days' notice. When you become aware of a need for FMLA leave less than 30 days in advance, you must provide notice of the need for the leave as soon as practicable, generally either the same day or the next business day. When the need for FMLA leave is not foreseeable, you must provide notice to the maximum extent possible and you must comply with Venable’s customary sick leave notice requirements. P. Designation of FMLA Leave Within five business days after you have submitted the appropriate certification form, the Manager, Benefits & Wellness will complete and provide you with a response to your request for FMLA leave using the Department of Labor Designation Notice. Absent extenuating circumstances, if the Firm determines that the leave is being taken for an FMLA-qualifying reason, the Firm reserves the right to designate the leave as FMLA leave, regardless of any paid leave you are required or eligible to take, and regardless of whether you have requested FMLA leave. Q. Intent to Return to Work from FMLA Leave When on FMLA leave, you are required to keep HR informed of any leave status changes and to stay in contact with your supervisor about your expected return to work date.

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R. Return to Work Subject to the requirements of applicable law, any Firm Personnel on an approved leave of absence (medical, personal, or otherwise) will terminate employment from the Firm on the earliest of the following: • On the date the person resigns from the Firm; • On the date the person accepts or begins employment outside the Firm, in the Firm’s discretion; • 30 days after the person’s doctor releases him/her to return to work (with or without reasonable accommodation), but the person does not return within that 30-day period; • After 12 months of leave within a consecutive 18-month period; • Immediately following a failure to return from an approved personal leave of absence. The term “Firm Personnel” shall mean each person employed by Venable in any capacity, including legal, professional staff or other, excluding Equity Partner. The Firm reserves the right and discretion to administer and interpret this policy and to determine all questions regarding its applicability in any circumstance. This policy does not modify the Firm’s non-medical leave of absence policy.

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S. Conclusion The provisions set forth above are a brief summary of the entitlements and requirements under the FMLA. It is our intention to administer the policy in a manner consistent with the FMLA and the regulations issued by the Secretary of Labor. T. LEAVE FOR DEPLOYMENT OF FAMILY MEMBERS IN THE ARMED FORCES (STATE OF MARYLAND) Employees based in our Maryland offices are eligible for leave for deployment of family members in the armed forces if you have worked for Venable for the last 12 months, whether consecutive or intermittent, and worked at least 1,250 hours during the 12-month period preceding the leave. The leave period is one day of leave on the day that an immediate family member (parent, stepparent, spouse, child or stepchild) is leaving for or returning from active duty outside of the U.S. as a member of the armed forces of the U.S. Employees may not be required to use PTO or sick leave. Venable may require documentation verifying that the leave is taken for this qualifying reason. In addition, an employee in our Maryland offices may be eligible for up to 15 days of leave to serve in an emergency called by the Maryland Wing of the Civil Air Patrol, with the option to use accrued unused paid leave. For more information, contact benefits@venable.com. U. REASONABLE ACCOMODATIONS FOR DISABILITIES DUE TO PREGNANCY (MARYLAND) If employees based in our Maryland offices incur a disability as a result of or contributed to by pregnancy, they have the right to request a reasonable accommodation that may include:

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• changing their job duties; • changing their work hours; • relocating their work area; • providing mechanical or electrical aids; • transferring them to a less strenuous or less hazardous position; or • providing leave; and • not imposing an undue hardship upon the Company.

You may be required to provide medical certification of the need for reasonable accommodation to the same extent a certification is required for other temporary disabilities. Such certification shall include: • the date the reasonable accommodation became medically advisable; • the probable duration of the reasonable accommodation; and • an explanatory statement as to the medical advisability of the reasonable accommodation. Venable policies and practices regarding the availability of leave, the accrual of seniority and other benefits and privileges, reinstatement, and payment under any health or temporary disability insurance or sick leave plan, formal or informal, shall be applied to disability due to pregnancy or childbirth on the same terms and conditions as they are applied to other temporary disabilities.

Please email benefits@venable.com for additional information.

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V. REASONABLE ACCOMMODATIONS FOR DISABILITIES DUE TO PREGNANCY (DELAWARE) Venable will provide reasonable accommodation for the known limitations of an employee due to pregnancy, childbirth, lactation, and related conditions. If you need accommodation under this policy, contact benefits@venable.com.

W. REASONABLE ACCOMMODATIONS FOR DISABILITIES DUE TO PREGNANCY (VIRGINIA)

If employees based in our Virginia office incur a disability or limitations as a result of or contributed to by pregnancy, childbirth, or related medical conditions, they have the right to request a reasonable accommodation that may include: • frequent or longer bathroom breaks and breaks to express breast milk; • access to a private location other than a bathroom for the expression of breast milk; • acquisition or modification of equipment or access to or modification of employee seating; • a temporary transfer to a less strenuous or hazardous position; • assistance with manual labor; • job restructuring; • a modified work schedule;

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• light duty assignments; and • leave to recover from childbirth.

Venable will engage in a timely, good faith, interactive process with you when you request an accommodation to determine if the requested accommodation is reasonable or presents an undue hardship for the Firm. You may be required to provide medical certification of the need for reasonable accommodation to the same extent a certification is required for other temporary disabilities. Such certification may include: • the date the reasonable accommodation became medically advisable; • the probable duration of the reasonable accommodation; and • an explanatory statement as to the medical advisability of the reasonable accommodation. Venable policies and practices regarding the availability of leave, the accrual of seniority and other benefits and privileges, reinstatement, and payment under any health or temporary disability insurance or sick leave plan, formal or informal, shall be applied to disability due to pregnancy or childbirth on the same terms and conditions as they are applied to other temporary disabilities. Venable prohibits unlawful discrimination on the basis of pregnancy, childbirth, or related medical conditions.

Please email benefits@venable.com for additional information.

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DISTRICT OF COLUMBIA - FAMILY AND MEDICAL LEAVE In addition to the Family and Medical Leave provisions set forth in the Firm’s FMLA policy, the following policies apply for employees working in the Firm’s Washington, DC office: It is the policy of Venable to grant periods of leave to employees who request time off for family or medical reasons, in accordance with the Federal Family and Medical Leave Act of 1993 (FMLA) and the District of Columbia Family and Medical Leave Act (DC FMLA), whichever is deemed to be more generous. Eligibility. You are eligible for leave under the Act if (1) you have been employed by Venable for at least one year without a break in service (except for regular holiday, sick, or personal leave granted by Venable) in the seven years immediately preceding the date of the DC FMLA request, and (2) you have worked at least 1,000 hours (inclusive of regular holiday, sick, or personal leave granted by Venable) during the 12-month period immediately preceding the DC FMLA request.

Reasons for Leave. You may request family leave under the DC FMLA for the following reasons:

1) the birth of your child;

2) the placement of a child with you for adoption or foster care, or for whom you permanently assume and discharge parental responsibility; or

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