The Period Pantry.

1. Purpose

The Period Pantry (“Organization”) is committed to providing equal access to employment, volunteer service, programs, and other Organization activities. This Accommodations Policy for Disability and Religious Practices establishes a clear, respectful process for requesting and evaluating reasonable accommodations.

This policy is intended to comply with applicable federal, state, and local law, including the Americans with Disabilities Act (ADA), the ADA Amendments Act, Section 504 of the Rehabilitation Act where applicable, Title VII of the Civil Rights Act of 1964, and applicable Maryland laws. The Organization will provide reasonable accommodations to qualified individuals with disabilities and to individuals whose sincerely held religious beliefs or practices conflict with a work, volunteer, program, or participation requirement, unless doing so would create an undue hardship as defined by law.

This policy addresses two accommodation types:

• Disability accommodations: adjustments or modifications that enable a qualified individual with a disability to perform the essential functions of a role or access an Organization activity.
• Religious accommodations: adjustments or modifications that enable an individual to observe a sincerely held religious belief or practice while participating in work or an Organization activity.

2. Scope

This policy applies to applicants, employees, interns, volunteers, student ambassadors, contractors, consultants, and other individuals participating in or seeking to participate in The Period Pantry’s work, programs, events, services, and activities, to the extent required by applicable law and appropriate to the individual’s relationship with the Organization.

It applies to requests related to recruitment, applications, interviews, onboarding, work assignments, schedules, volunteer shifts, meetings, trainings, community events, school-based activities, remote participation, and other Organization settings. The Organization will consider each request individually and will not make assumptions based on a diagnosis, religion, appearance, or prior accommodation.

3. Disability Accommodations

3.1 General Policy

The Period Pantry will provide reasonable accommodations to a qualified individual with a disability when the individual can perform the essential functions of the position or participate in the applicable activity with or without accommodation. A disability may be physical or mental and may substantially limit one or more major life activities, as defined by applicable law. The Organization will consider reasonable accommodations that are effective, appropriate to the individual’s needs, and compatible with essential program, safety, and operational requirements.

An accommodation may be requested before an individual begins work or service, or at any time afterward. An individual does not need to use legal terminology or submit a written request to begin the process. A request may be made by the individual, by a family member or other representative acting with the individual’s permission, or by another person who is assisting the individual.

3.2 Examples of Disability Accommodations

Depending on the circumstances, reasonable disability accommodations may include:

• Making a facility, workspace, meeting location, event, or program physically accessible;
• Providing an accessible parking space or a location closer to an entrance;
• Providing accessible formats, such as large print, electronic text, captioned video, or screen-reader-compatible documents;
• Providing a qualified sign-language interpreter, reader, or other communication support;
• Providing or permitting assistive technology, adaptive equipment, or other reasonable devices;
• Modifying the way instructions, training, or information are communicated;
• Adjusting a schedule, start time, end time, break schedule, or volunteer shift;
• Allowing periodic rest breaks or time for disability-related treatment;
• Permitting remote or hybrid participation when the essential functions or activity requirements can be met remotely;
• Modifying nonessential job duties, procedures, or methods of performing a task;
• Restructuring a position or reallocating marginal duties, when appropriate;
• Providing leave when it is a reasonable accommodation and does not create an undue hardship;
• Permitting a service animal or other reasonable modification related to an animal assisting with a disability;
• Adjusting a workspace, workstation, seating arrangement, lighting, sound, or environmental conditions;
• Reassigning an employee to a vacant position for which the employee is qualified, when reassignment is a reasonable accommodation and other accommodations are not effective; and
• Making another reasonable adjustment that enables the qualified individual to perform essential functions or participate meaningfully and safely.

3.3 Qualified Individual

A qualified individual is an individual who satisfies the legitimate skill, experience, education, conduct, and other requirements of the position or activity and who can perform its essential functions, with or without reasonable accommodation. The Organization will identify essential functions and evaluate qualifications based on objective, job-related or activity-related criteria. An individual who poses a direct threat to the health or safety of the individual or others will not be excluded unless the threat cannot be eliminated or reduced to an acceptable level through reasonable accommodation.

4. Religious Accommodations

4.1 General Policy

The Period Pantry will provide a reasonable accommodation for an individual’s sincerely held religious belief, observance, or practice when the belief, observance, or practice conflicts with a work, volunteer, program, or participation requirement, unless the accommodation would impose an undue hardship on the Organization. Religious beliefs may be unfamiliar, nontraditional, or held by a small number of people. The Organization will not evaluate the truth or reasonableness of a religious belief; it will evaluate the sincerity of the belief and the effectiveness and feasibility of the requested accommodation.

Religious accommodations may be requested for practices connected to a religion, faith, or system of religious belief. A request does not need to mention Title VII or use the words “religious accommodation” to receive consideration.

4.2 Examples of Religious Accommodations

Depending on the circumstances, reasonable religious accommodations may include:

• Adjusting a work schedule, volunteer shift, meeting time, or event assignment;
• Providing time away from work or service for prayer, worship, religious instruction, or observance;
• Allowing use of an appropriate private or reasonably designated space for prayer or religious practice;
• Providing unpaid leave or a schedule change for religious holidays or holy days;
• Permitting voluntary shift swaps or substitutions that do not create a burden for another individual;
• Modifying a dress, uniform, grooming, or appearance requirement to permit religious clothing, hair, or grooming practices;
• Modifying food, meal, or event arrangements to address religious dietary requirements;
• Adjusting participation in activities that conflict with a sincerely held religious practice;
• Permitting remote or alternative participation when the essential requirements can be met in that manner;
• Providing an alternative task, assignment, or method of completing a requirement when appropriate; and
• Making another reasonable adjustment that allows the individual to observe the religious belief or practice.

5. Requesting an Accommodation

5.1 Who May Request

An applicant, employee, volunteer, intern, student ambassador, contractor, consultant, or other participant may request an accommodation for the individual’s own disability or sincerely held religious belief or practice. A family member, medical provider, religious leader, support person, or other representative may help communicate a request with the individual’s permission. Supervisors and coordinators who become aware that an individual may need an accommodation must promptly refer the matter to the Executive Director and must not discourage the individual from making a request.

5.2 How to Request

Requests may be made verbally or in writing to a supervisor, coordinator, the Executive Director, or another contact listed in Section 13. The request should identify the barrier or conflict, the accommodation being requested if known, and the timing or duration of the need. The Organization will consider a request as soon as it receives enough information to understand that an adjustment may be needed, even if the request is informal or incomplete.

Individuals are encouraged to make requests as early as possible, especially when the accommodation relates to a known schedule, event, training, or religious observance. A late request will still be considered, and the Organization will respond as promptly as practicable.

5.3 Emergency Requests

If an immediate accommodation is needed because of an urgent health, safety, access, or religious-observance concern, the individual should tell the nearest supervisor, coordinator, or event lead and contact the Executive Director as soon as possible. The Organization may provide an interim accommodation while it gathers information and evaluates a longer-term solution. Emergency steps will be handled with appropriate attention to safety, privacy, and continuity of the Organization’s operations.

6. Interactive Process

The Period Pantry will engage in a timely, good-faith interactive process with the individual requesting an accommodation. The process may include the following steps:

1. Receive the request: The Organization will acknowledge the request and identify the person responsible for coordinating the response.
2. Clarify the need: The Organization will discuss the barrier, conflict, essential functions or requirements, expected duration, and requested timing.
3. Invite the individual’s input: The individual may identify possible accommodations and explain how each option would address the need.
4. Request limited information when necessary: The Organization may seek reasonable information needed to understand the limitation or religious conflict and evaluate an effective accommodation.
5. Identify options: The Organization and the individual will consider the requested accommodation and other effective alternatives.
6. Evaluate feasibility: The Organization will consider effectiveness, safety, essential functions, program requirements, cost, resources, scheduling, and any undue hardship.
7. Select an accommodation: When more than one effective accommodation is available, the Organization may choose the option that is effective and operationally reasonable.
8. Communicate the decision: The Organization will explain the approved accommodation, any limitations, the expected start date, and any follow-up requirements. If a request is denied, the Organization will explain the reason to the extent appropriate.
9. Follow up and adjust: The Organization will monitor the accommodation and revisit it when circumstances, the individual’s needs, the role, the activity, or applicable law changes.

7. Documentation

7.1 Disability-Related Documentation

When a disability or the need for an accommodation is not obvious, the Organization may request limited documentation from an appropriate health care or rehabilitation professional. The documentation should explain the functional limitation, the accommodation needed, and the expected duration when that information is necessary to evaluate the request. The Organization will not request unrelated medical information, a complete medical history, or information beyond what is reasonably necessary.

Documentation will not be required when the disability and need for accommodation are obvious or already known, when the individual has provided sufficient information, or when applicable law prohibits the request. The Organization may consult with a professional, at its expense when required by law, if the information provided is insufficient or inconsistent.

7.2 Religious Documentation

The Organization will ordinarily rely on the individual’s statement that a religious belief or practice is sincerely held and conflicts with a requirement. When there is a reasonable, objective basis to question sincerity or clarify the conflict, the Organization may ask limited, respectful questions or request additional information about the religious practice. The Organization will not require proof from a religious organization or demand that a belief be part of an established religion.

7.3 Failure to Provide Reasonable Information

If an individual does not provide information that is reasonably necessary to evaluate a request after the Organization has explained what is needed and allowed a reasonable opportunity to respond, the Organization may be unable to approve the requested accommodation. The Organization will continue the interactive process when possible and will consider any information the individual later provides.

8. Confidentiality and Privacy

Information about a disability, medical condition, religious belief, religious practice, or accommodation request will be treated as confidential and will be maintained separately from general personnel, volunteer, or program records when appropriate. Access will be limited to individuals who need the information to evaluate, implement, administer, or monitor the accommodation, respond to an emergency, or comply with applicable law.

Supervisors and coordinators will be told only the information necessary to implement restrictions or work and participation conditions. They will not be told a diagnosis or private religious information unless disclosure is necessary and permitted. The Organization will protect records from unauthorized access and will not use accommodation information for retaliation, discrimination, or any purpose unrelated to the request, except as permitted or required by law.

9. Undue Hardship

The Organization is not required to provide an accommodation that would impose an undue hardship. Undue hardship will be evaluated under the legal standard applicable to the type of request and the individual’s relationship with the Organization. The Organization will not rely on generalized assumptions or minor inconvenience alone.

When evaluating undue hardship, the Organization may consider:

• The nature and cost of the accommodation;
• The Organization’s overall financial resources and the resources of the relevant program or operation;
• The number of people affected and the effect on expenses, staffing, schedules, or operations;
• The effect on the Organization’s ability to conduct its mission, deliver services, operate programs, or meet commitments;
• The effect on workplace, participant, volunteer, or community safety;
• The accommodation’s effect on the essential functions or requirements of the position or activity;
• The availability of alternative accommodations that are effective and less burdensome;
• Whether the accommodation would require a fundamental alteration to a program, service, or operation;
• Whether the accommodation would violate another law, regulation, grant condition, contractual requirement, or health and safety standard;
• For religious accommodations, the practical impact on coworkers, volunteers, participants, scheduling, and operations, as evaluated under applicable law; and
• Any other facts required by applicable law or relevant to the specific request.

If a requested accommodation would create an undue hardship, the Organization will consider whether another effective accommodation is available.

10. No Retaliation

The Period Pantry prohibits retaliation against any person who requests an accommodation, provides information about a request, participates in the interactive process, supports another person’s request, opposes discrimination, reports a concern, or exercises a right protected by law. Retaliation includes intimidation, threats, harassment, reduced hours or opportunities, undesirable assignments, exclusion, negative treatment, or any action that could discourage a reasonable person from requesting an accommodation or raising a concern.

A request will not be denied or treated negatively because the requested accommodation is ultimately not required, cannot be provided, or is replaced by another effective accommodation. A good-faith request is protected even when the Organization concludes that the individual is not eligible or that no reasonable accommodation is available.

11. Responsibilities

11.1 The Period Pantry

The Organization is responsible for maintaining an accessible process, responding promptly, engaging in a good-faith interactive process, evaluating requests individually, protecting confidential information, implementing approved accommodations, and training those who may receive or administer requests. The Organization will maintain appropriate records and review this policy as needed.

11.2 Supervisors and Coordinators

Supervisors and coordinators must listen respectfully, recognize that ordinary language may communicate a request, avoid making medical or religious judgments, and refer requests promptly to the Executive Director. They must not promise a result, deny a request independently, ask for unnecessary personal information, disclose private information, or retaliate against an individual. They are responsible for implementing approved accommodations and promptly reporting any problem with implementation.

11.3 Individuals Requesting Accommodation

Individuals requesting accommodation are responsible for communicating the need as soon as practicable, providing reasonable information when requested, participating in the interactive process, considering effective alternatives, following applicable safety and operational requirements, and promptly communicating if an approved accommodation is not effective or circumstances change. An individual is not required to disclose more private information than is reasonably necessary to evaluate the request.

12. Prohibited Conduct

The Period Pantry prohibits discrimination, harassment, retaliation, intimidation, or interference based on disability, perceived disability, association with a person with a disability, religion, religious belief, religious practice, or request for accommodation. Prohibited conduct includes:

• Refusing to consider a request or discouraging an individual from making a request;
• Demanding unnecessary medical or religious information or sharing confidential information without authorization;
• Mocking, insulting, stereotyping, or making derogatory comments about a disability, religion, belief, practice, accommodation, assistive device, service animal, or religious clothing;
• Imposing a requirement that conflicts with a known disability-related limitation or sincerely held religious practice without considering an accommodation;
• Taking adverse action against an individual for requesting, receiving, using, or supporting an accommodation;
• Interfering with an approved accommodation or failing to follow the implementation plan; and
• Knowingly providing false information or abusing the accommodation process in bad faith.

Conduct that violates this policy may result in corrective action, up to and including removal from an activity, ending a volunteer or contractor engagement, or termination of employment, consistent with applicable law and the individual’s relationship with the Organization.

13. Reporting Concerns

Anyone who believes that an accommodation request was not handled appropriately, an approved accommodation was not implemented, confidential information was disclosed, or discrimination, harassment, retaliation, or other prohibited conduct occurred should report the concern as soon as possible. A report may be made verbally or in writing to the Executive Director or another supervisor, coordinator, or authorized representative. The Organization will review concerns promptly and as confidentially as practicable. Individuals may also contact a government agency or seek other assistance available under applicable law.

14. No Waiver of Legal Rights

This policy does not limit or waive any right, protection, remedy, or procedure available under federal, state, or local law. Nothing in this policy prevents an individual from contacting a government agency, filing a charge or complaint, participating in an investigation, seeking legal advice, or exercising any other protected right. If this policy provides less protection than applicable law, the law controls.

15. Governing Law

This policy will be interpreted and applied in accordance with applicable federal law, the laws of the State of Maryland, and any applicable local law. If any provision of this policy is found to be invalid or unenforceable, the remaining provisions will remain in effect to the fullest extent permitted by law.

16. Acknowledgment and Approval

I acknowledge that I have received, read, and understand The Period Pantry’s Accommodations Policy for Disability and Religious Practices. I understand that the policy explains how to request an accommodation, participate in the interactive process, protect confidential information, and report concerns. I understand that I am expected to cooperate in good faith, respect the privacy and dignity of others, comply with this policy, and avoid retaliation or other prohibited conduct. I understand that this acknowledgment does not waive any legal right or create a contract of employment or service. I may ask questions or request an accommodation through the contact information in Section 13.