1008-00004 · Client 1008 · Recruitment

notice-of-filing-internal-posting-template.docx DOCUMENT Funds

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NOTICE OF FILING — PERM LABOR CERTIFICATION APPLICATION

Internal Job Posting — 10 Consecutive Business Day Worksite Notice

Pursuant to 20 CFR §656.10(d)

TEMPLATE — TO BE COMPLETED FOR EACH POSITION

Prepared by: Tiffany Rosenthal, Esq. Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104

Prepared for: Lumos Analytics Inc.

Matter Number: 1008-00004

This notice must be posted in a conspicuous location at the employee worksite for a period of 10 consecutive business days. A copy of this completed notice must be retained in the PERM audit file. Failure to comply with the posting requirements set forth in 20 CFR §656.10(d) may result in denial of the permanent labor certification application.

Section 1: Employer Information

Employer Name: Lumos Analytics Inc.

Employer Address (Worksite / Principal Place of Employment): 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303

Federal Employer Identification Number (EIN): 84-3291057

Entity Type: Delaware C-Corporation, qualified to do business in the State of California

Industry: Enterprise SaaS / Fintech — AI-driven credit risk analytics and automated underwriting platform

Contact for Applications and Inquiries: ________

(To be completed — for Lumos cases, the designated HR contact is Janelle Kwon, HR Manager)

Contact Email: ________

Contact Phone: ________

Section 2: Purpose of This Notice

This notice is posted in connection with the filing of an Application for Permanent Employment Certification (ETA Form 9089) by Lumos Analytics Inc. with the U.S. Department of Labor, Office of Foreign Labor Certification, pursuant to 20 CFR Part 656 (the "PERM" program).

Lumos Analytics Inc. is seeking to sponsor a foreign national employee for lawful permanent residence (commonly referred to as a "green card") in the United States under the Employment-Based Second Preference (EB-2) immigrant visa classification. The EB-2 classification is designated for professionals holding an advanced degree, or the equivalent thereof, who are being offered a position that requires such qualifications. The foreign national being sponsored holds qualifications at the Advanced Degree Professional level as defined under Section 203(b)(2) of the Immigration and Nationality Act, 8 U.S.C. §1153(b)(2).

This posting constitutes a mandatory step in the PERM labor certification recruitment process. Under Department of Labor regulations at 20 CFR §656.10(d), an employer filing a PERM application must provide notice of the filing to its employees at the worksite where the offered position will be located. This notice satisfies that requirement. The purpose of the PERM labor certification process is to ensure that the employment of the foreign national in the offered position will not adversely affect the wages and working conditions of similarly employed U.S. workers, and that there are no qualified, willing, able, and available U.S. workers for the position.

Section 3: Job Opportunity Information

3.1 Job Title

Job Title: ________

(Template instruction: Insert the job title exactly as it will appear on ETA Form 9089. The job title must accurately reflect the position being offered and must be consistent across all PERM filings and recruitment materials. For Lumos cases, the four positions requiring separate postings are: (1) VP, Engineering — Core Platform; (2) Senior Director, Data Science & Machine Learning; (3) VP, Product — Fintech Solutions; and (4) Director, Information Security & Compliance.)

3.2 Standard Occupational Classification (SOC) Code and Title

SOC Code: ________

SOC Title: ________

(Template instruction: Insert the SOC code assigned to this position as reflected on the approved prevailing wage determination from the National Prevailing Wage Center (NPWC). The SOC code must correspond to the occupational classification that most accurately describes the duties of the position as offered. For Lumos cases, the applicable SOC codes are as follows: VP, Engineering — Core Platform: SOC 15-1252, Software Developers; Senior Director, Data Science & Machine Learning: SOC 15-2051, Data Scientists; VP, Product — Fintech Solutions: SOC 11-2021, Marketing Managers; Director, Information Security & Compliance: SOC 15-1212, Information Security Analysts.)

3.3 Job Duties

Description of Job Duties:

________________________________________

(Template instruction: Provide a full and detailed description of the duties of the position as they will appear on ETA Form 9089, Section H. The duties described herein must reflect the actual requirements of the job opportunity and must not be tailored to match the specific qualifications, experience, or background of any particular individual, including the foreign national beneficiary. Duties should be described in sufficient detail to enable a prospective applicant to evaluate whether he or she is qualified for the position. Where possible, indicate the approximate percentage of time devoted to each major duty category.)

3.4 Minimum Education Requirements

Minimum Degree Level Required: ________

Required Field(s) of Study: ________

(Template instruction: State the minimum educational requirement for the position exactly as it will appear on ETA Form 9089. For positions classified under the EB-2 Advanced Degree Professional category, the minimum educational requirement must be at least a U.S. Master's degree or its foreign equivalent in a relevant field of study, or alternatively, a U.S. Bachelor's degree or its foreign equivalent in a relevant field of study plus five (5) years of progressive post-baccalaureate experience in the specialty. The educational requirement stated must reflect the employer's actual minimum requirement for the position and must be consistent with what is customary in the industry for the occupation in question. Any alternative acceptable degree fields must also be listed.)

3.5 Minimum Experience Requirements

Minimum Years of Experience Required: ________

Description of Required Experience: ________

________________________________________

(Template instruction: State the minimum number of years and type of professional experience required for the position. Experience requirements must reflect the employer's actual minimum requirements for the position and must not exceed what is customary and standard for the occupation within the industry. If the experience requirement includes specialized or progressive experience in a particular area, describe that area with specificity. Note that under 20 CFR §656.17(i), experience gained with the sponsoring employer may be credited toward the minimum requirements only under certain limited conditions — consult with Calderwood & Harkness LLP before specifying any experience requirement that the beneficiary satisfies through employment with Lumos Analytics Inc.)

3.6 Special Skills, Certifications, or Other Requirements

Special Skills, Professional Certifications, Licenses, or Other Requirements:

________________________________________

(Template instruction: List any special skills, professional certifications, licenses, language requirements, or other requirements for the position. Each special requirement must be justified by business necessity and must reflect the actual minimum requirements of the position as it exists within the employer's organization. Special requirements must not be unduly restrictive and must not be designed to preclude otherwise qualified U.S. workers from consideration. Examples of special requirements for the Lumos cases may include, but are not limited to: CISSP (Certified Information Systems Security Professional) certification for the Director, Information Security & Compliance position; demonstrated experience with specific technologies such as Apache Kafka, Kubernetes, TensorFlow, or PyTorch; a record of peer-reviewed publications in relevant scientific or technical journals; and/or experience with specific regulatory frameworks such as the Fair Credit Reporting Act (FCRA), the Equal Credit Opportunity Act (ECOA), the Gramm-Leach-Bliley Act (GLBA), or SOC 2 compliance standards. Each special requirement listed herein must be documented with a business necessity justification and retained in the PERM audit file.)

3.7 Offered Salary

Annual Salary Offered: $________ per year

(Template instruction: The offered salary must meet or exceed the prevailing wage as determined by the National Prevailing Wage Center (NPWC) for the applicable SOC code and geographic area. The prevailing wage area for the Lumos Analytics Inc. worksite at 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303 falls within the San Jose-Sunnyvale-Santa Clara, CA Metropolitan Statistical Area (MSA), Office of Employment Statistics (OES) Area Code 41940. The offered wage must equal or exceed the applicable prevailing wage at the wage level assigned by the NPWC on the approved prevailing wage determination. Failure to offer a wage at or above the prevailing wage will result in denial of the PERM application. The employer must be able to demonstrate the ability to pay the offered wage as of the PERM priority date.)

3.8 Work Schedule and Conditions

Hours: Full-time position, minimum forty (40) hours per week.

Supervisory Responsibilities: ________

(Indicate Yes or No. If yes, describe the nature of supervisory responsibilities, including the number and types of direct reports.)

Travel Requirements: ________

(Indicate the approximate percentage of travel required, if any, and whether travel is domestic, international, or both.)

Other Conditions of Employment: ________

(Include any other material conditions of employment, such as on-call requirements, shift work, physical demands, or security clearance requirements.)

3.9 Location of Employment

Primary Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303

The offered position is based at the employer's principal office located at the address stated above. The foreign national employee will perform the majority of his or her job duties at this worksite. Any requirement for travel to client sites, other Lumos Analytics Inc. offices, or conference locations is described in Section 3.8 above.

Section 4: Filing Information

Immigrant Visa Classification: EB-2 — Employment-Based Second Preference (Advanced Degree Professional), pursuant to Section 203(b)(2) of the Immigration and Nationality Act, 8 U.S.C. §1153(b)(2)

Federal Agency Receiving Application: U.S. Department of Labor, Employment and Training Administration, Office of Foreign Labor Certification (OFLC), Atlanta National Processing Center

Application Type: ETA Form 9089 — Application for Permanent Employment Certification

PERM Case Number (if assigned): ________

Date of PERM Filing (or Anticipated Filing Date): ________

(Template instruction: If the PERM application has not yet been filed with the Department of Labor at the time this notice is posted at the worksite, state the anticipated filing date. If the PERM application has already been filed, state the actual filing date and the assigned PERM case number. The case number is typically in the format A-XXXXX-XXXXX. Note that under 20 CFR §656.17(f), the PERM application must not be filed earlier than 30 days after the date the SWA job order is placed and not later than 180 days after the date recruitment has been completed. Coordinate filing dates with Calderwood & Harkness LLP.)

Section 5: How to Apply / Employee Notification

Any person may apply for this position. U.S. workers — including U.S. citizens, U.S. nationals, lawful permanent residents, asylees, and refugees — who believe they are qualified for this position are encouraged to apply. There is no requirement that applicants currently be employed by Lumos Analytics Inc. in order to be considered for the position described in this notice.

How to Submit an Application:

Applications should be submitted in writing to the following contact at Lumos Analytics Inc.:

________________________________________

(Contact Name)

________________________________________

(Title)

Lumos Analytics Inc. 2240 Embarcadero Way, Suite 600 Palo Alto, CA 94303

Email submissions may be sent to: ________

Applications must include a current resume or curriculum vitae (CV) detailing the applicant's education, professional experience, certifications, and other qualifications relevant to the minimum requirements described in Section 3 of this notice. Applicants are encouraged to provide sufficient detail regarding their qualifications to permit a thorough evaluation of their candidacy.

Evaluation of Applications: Applications will be reviewed and evaluated solely based on the minimum education, experience, and other requirements stated in this posting. All applicants will be assessed using the same lawful, job-related criteria without regard to any characteristic protected under applicable federal, state, or local law. No applicant will be given preference or subjected to disfavor based on any factor other than his or her qualifications as measured against the stated requirements of the position.

No Obligation to Hire: This posting does not obligate Lumos Analytics Inc. to hire any applicant and does not create an employment contract or a promise of employment. The employer will consider all qualified applicants in accordance with applicable U.S. Department of Labor regulations governing the PERM labor certification process, including 20 CFR Part 656. Lumos Analytics Inc. reserves all rights afforded to employers under applicable law regarding hiring decisions for this position.

Section 6: Posting Period and Compliance

Date Posted: ________

Date Removed (10th Consecutive Business Day): ________

Posting Location(s):

________________________________________

(Describe the specific conspicuous location(s) at 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303 where this notice is physically displayed. The location(s) must be areas where notices to employees are customarily posted and where the notice is reasonably likely to be seen by all employees at the worksite. Suitable locations include, but are not limited to: employee break room bulletin board, main lobby entrance bulletin board, HR department bulletin board, or common area adjacent to the elevator bank on the 6th floor. If the notice is posted in multiple locations, list each location.)

This notice must remain posted for a minimum of ten (10) consecutive business days in accordance with 20 CFR §656.10(d). Business days do not include weekends or federal holidays. The notice must not be removed, obscured, or relocated during the mandatory posting period. If the notice is inadvertently removed or becomes illegible during the posting period, it must be reposted and the 10-business-day count must restart from the date of reposting.

Compliance Certification. I certify that this notice was posted in a conspicuous location at the worksite described above on the date indicated and was removed on the date indicated, having been posted for at least ten (10) consecutive business days in compliance with the requirements of 20 CFR §656.10(d). I further certify that the notice was posted in a location where it was reasonably accessible to and could be seen by all employees at the worksite, and that the notice was not removed, obscured, defaced, or relocated at any time during the posting period.

Signature of Authorized Representative: ________

Printed Name: ________

Title: ________

Date: ________

Section 7: Non-Discrimination Statement

Lumos Analytics Inc. is an equal opportunity employer. This notice is posted pursuant to federal regulatory requirements in connection with the PERM labor certification process under 20 CFR Part 656 and does not reflect any preference for or against any applicant on the basis of national origin, citizenship status, or immigration status, except as required or permitted by applicable law.

All qualified applicants will receive consideration for the position described in this notice without regard to race, color, religion, sex (including pregnancy, childbirth, and related medical conditions), sexual orientation, gender identity, gender expression, national origin, ancestry, age, disability, genetic information, veteran status, military service, marital status, or any other characteristic protected by applicable federal, state, or local law, including but not limited to the California Fair Employment and Housing Act (Cal. Gov. Code §12900 et seq.) and Title VII of the Civil Rights Act of 1964, as amended (42 U.S.C. §2000e et seq.).

Section 8: Additional Regulatory Notices

The filing of an application for permanent employment certification with the U.S. Department of Labor does not constitute a guarantee of employment to any applicant, nor does it guarantee that the application will be approved by the Department of Labor. The PERM labor certification process is a regulatory procedure through which the Department of Labor evaluates whether there are sufficient qualified U.S. workers available for the position offered and whether the employment of a foreign national in the position would adversely affect the wages and working conditions of similarly employed U.S. workers.

Questions regarding the PERM labor certification process, including the regulatory requirements governing the filing of ETA Form 9089 and the recruitment procedures applicable to professional occupations, may be directed to the U.S. Department of Labor, Office of Foreign Labor Certification. General information about the PERM program is available on the Department of Labor's Foreign Labor Certification website at https://www.dol.gov/agencies/eta/foreign-labor.

The employer's immigration counsel for this matter is:

Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104 Matter No. 1008-00004

All inquiries from prospective applicants regarding the position itself should be directed to the employer contact identified in Section 1 of this notice, not to the employer's immigration counsel.

— FOR INTERNAL USE ONLY —

INSTRUCTIONS TO LUMOS ANALYTICS INC. HR TEAM

DO NOT POST THIS PAGE

To: Janelle Kwon, HR Manager, Lumos Analytics Inc. From: Tiffany Rosenthal, Calderwood & Harkness LLP Re: Completion and Posting Instructions — PERM 10-Day Worksite Notice Template Matter No.: 1008-00004

General Instructions:

This template must be completed separately for each of the four beneficiary positions for which PERM labor certification applications are being filed by Lumos Analytics Inc. Each completed posting must contain the specific job title, SOC code, job duties, minimum requirements, and offered salary applicable to the individual position. Under no circumstances should a single posting be used to cover more than one position.

The four positions requiring separate postings are as follows:

IMPORTANT — Beneficiary Name Confidentiality: The beneficiary's name must NOT appear anywhere on the posted notice. The worksite posting is required to describe the job opportunity and the terms and conditions of employment; it is not required to identify, and must not identify, the foreign national employee being sponsored. The inclusion of the beneficiary's name on the posted notice could compromise the integrity of the recruitment process and may raise issues in the event of a PERM audit. All four postings should be reviewed carefully before posting to confirm that the beneficiary's name does not appear.

Posting Schedule:

• Campaign 1 (Rajan Mehta — VP, Engineering and Lina Varga — Senior Director, Data Science): The worksite postings for these two positions are to be coordinated with the broader recruitment campaign commencing on October 9, 2023. The notices should be posted on or before October 9, 2023 and should remain posted for a minimum of 10 consecutive business days. Assuming posting on October 9, 2023 (Monday), and excluding weekends and the Columbus Day federal holiday (October 9, 2023), the earliest permissible removal date should be calculated accordingly. Please consult with Calderwood & Harkness LLP to confirm the exact removal date.

• Campaign 2 (Tomás Aguilar-Reyes — VP, Product and Yumiko Tanaka — Director, Information Security): The worksite postings for these two positions are to be coordinated with the broader recruitment campaign commencing on October 23, 2023. The notices should be posted on or before October 23, 2023 and should remain posted for a minimum of 10 consecutive business days. Please consult with Calderwood & Harkness LLP to confirm the exact removal date.

Post-Removal Documentation Requirements:

Upon removal of each posting at the conclusion of the 10-business-day posting period, the following steps must be completed:

1. The Compliance Certification in Section 6 of each posting must be completed and signed by an authorized representative of Lumos Analytics Inc. (Janelle Kwon or another authorized officer or manager).

2. A photograph or high-resolution scan of each posted notice in situ (i.e., as it appeared while physically posted at the worksite) must be taken prior to removal. The photograph should clearly show (a) the full text of the notice, and (b) the surrounding area sufficient to demonstrate that the notice was posted in a conspicuous location at the worksite.

3. The completed and signed certification, together with the photograph or scan, must be forwarded promptly to:

(a) Janelle Kwon, HR Manager, Lumos Analytics Inc. (internal retention copy); and

(b) Derek Okonkwo, Associate, Calderwood & Harkness LLP, 555 California Street, 32nd Floor, San Francisco, CA 94104 (email: dokonkwo@calderwoodharkness.com) — for inclusion in the PERM audit file.

Document Retention:

All recruitment documentation, including each completed worksite posting, the signed compliance certification, and the photograph or scan of the posted notice, must be retained for a minimum of five (5) years from the date of filing the PERM application or from the date the recruitment was conducted, whichever is later. This retention requirement is mandated by 20 CFR §656.10(f) and applies regardless of whether the PERM application is approved, denied, or withdrawn. Lumos Analytics Inc. should maintain these records in a secure and accessible location, organized by beneficiary name and PERM case number.

Coordination with Other Recruitment Steps:

Please note that the internal worksite posting is only one of several mandatory recruitment steps required for PERM applications filed for professional occupations. Broadgate Compliance Services LLC (contact: Gerald Fitzmorris, 1414 K Street NW, Suite 730, Washington, DC 20005) has been retained to handle the placement of the following additional mandatory recruitment advertisements on behalf of Lumos Analytics Inc.:

• Two print advertisements in a newspaper of general circulation (Sunday edition of the San Jose Mercury News);

• State Workforce Agency (SWA) job order filed with the California Employment Development Department (EDD);

• Online posting on a professional journal or trade publication website relevant to the occupation; and

• Additional recruitment steps as required under 20 CFR §656.17(e)(1) for professional occupations (three of ten additional steps).

The internal worksite posting described in this template is the sole responsibility of the Lumos Analytics Inc. HR team and is not being handled by Broadgate Compliance Services LLC. It is critical that the posting be completed, displayed, and documented in accordance with the instructions above, as the worksite posting is frequently a focus of Department of Labor audits of PERM applications.

Questions:

Any questions regarding the completion of this template, the calculation of posting dates, the documentation of the posting period, or any other aspect of the PERM recruitment process should be directed to:

Tiffany Rosenthal, Partner Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104

Phone: (415) 555-0138

Email: trosenthal@calderwoodharkness.com

Derek Okonkwo, Associate Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104

Phone: (415) 555-0142

Email: dokonkwo@calderwoodharkness.com

CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED — ATTORNEY WORK PRODUCT

This template and the instructions contained herein have been prepared by Calderwood & Harkness LLP for the exclusive use of Lumos Analytics Inc. in connection with the PERM labor certification applications identified above. This document is protected by the attorney-client privilege and the attorney work product doctrine. Any unauthorized disclosure, distribution, or reproduction of this document is strictly prohibited. Receipt of this document by any person other than the intended recipient does not constitute a waiver of any applicable privilege.

No.	Job Title	Beneficiary	SOC Code	SOC Title	Campaign
1	VP, Engineering — Core Platform	Rajan Mehta	15-1252	Software Developers	Campaign 1
2	Senior Director, Data Science & Machine Learning	Lina Varga	15-2051	Data Scientists	Campaign 1
3	VP, Product — Fintech Solutions	Tomás Aguilar-Reyes	11-2021	Marketing Managers	Campaign 2
4	Director, Information Security & Compliance	Yumiko Tanaka	15-1212	Information Security Analysts	Campaign 2

NOTICE OF FILING — PERM LABOR CERTIFICATION APPLICATION
Internal Job Posting — 10 Consecutive Business Day Worksite Notice
Pursuant to 20 CFR §656.10(d)
TEMPLATE — TO BE COMPLETED FOR EACH POSITION
Prepared by: Tiffany Rosenthal, Esq. Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104
Prepared for: Lumos Analytics Inc.
Matter Number: 1008-00004
This notice must be posted in a conspicuous location at the employee worksite for a period of 10 consecutive business days. A copy of this completed notice must be retained in the PERM audit file. Failure to comply with the posting requirements set forth in 20 CFR §656.10(d) may result in denial of the permanent labor certification application.
Section 1: Employer Information
Employer Name: Lumos Analytics Inc.
Employer Address (Worksite / Principal Place of Employment): 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303
Federal Employer Identification Number (EIN): 84-3291057
Entity Type: Delaware C-Corporation, qualified to do business in the State of California
Industry: Enterprise SaaS / Fintech — AI-driven credit risk analytics and automated underwriting platform
Contact for Applications and Inquiries: ________
(To be completed — for Lumos cases, the designated HR contact is Janelle Kwon, HR Manager)
Contact Email: ________
Contact Phone: ________
Section 2: Purpose of This Notice
This notice is posted in connection with the filing of an Application for Permanent Employment Certification (ETA Form 9089) by Lumos Analytics Inc. with the U.S. Department of Labor, Office of Foreign Labor Certification, pursuant to 20 CFR Part 656 (the "PERM" program).
Lumos Analytics Inc. is seeking to sponsor a foreign national employee for lawful permanent residence (commonly referred to as a "green card") in the United States under the Employment-Based Second Preference (EB-2) immigrant visa classification. The EB-2 classification is designated for professionals holding an advanced degree, or the equivalent thereof, who are being offered a position that requires such qualifications. The foreign national being sponsored holds qualifications at the Advanced Degree Professional level as defined under Section 203(b)(2) of the Immigration and Nationality Act, 8 U.S.C. §1153(b)(2).
This posting constitutes a mandatory step in the PERM labor certification recruitment process. Under Department of Labor regulations at 20 CFR §656.10(d), an employer filing a PERM application must provide notice of the filing to its employees at the worksite where the offered position will be located. This notice satisfies that requirement. The purpose of the PERM labor certification process is to ensure that the employment of the foreign national in the offered position will not adversely affect the wages and working conditions of similarly employed U.S. workers, and that there are no qualified, willing, able, and available U.S. workers for the position.
Section 3: Job Opportunity Information
3.1 Job Title
Job Title: ________
(Template instruction: Insert the job title exactly as it will appear on ETA Form 9089. The job title must accurately reflect the position being offered and must be consistent across all PERM filings and recruitment materials. For Lumos cases, the four positions requiring separate postings are: (1) VP, Engineering — Core Platform; (2) Senior Director, Data Science & Machine Learning; (3) VP, Product — Fintech Solutions; and (4) Director, Information Security & Compliance.)
3.2 Standard Occupational Classification (SOC) Code and Title
SOC Code: ________
SOC Title: ________
(Template instruction: Insert the SOC code assigned to this position as reflected on the approved prevailing wage determination from the National Prevailing Wage Center (NPWC). The SOC code must correspond to the occupational classification that most accurately describes the duties of the position as offered. For Lumos cases, the applicable SOC codes are as follows: VP, Engineering — Core Platform: SOC 15-1252, Software Developers; Senior Director, Data Science & Machine Learning: SOC 15-2051, Data Scientists; VP, Product — Fintech Solutions: SOC 11-2021, Marketing Managers; Director, Information Security & Compliance: SOC 15-1212, Information Security Analysts.)
3.3 Job Duties
Description of Job Duties:
________________________________________
________________________________________
________________________________________
________________________________________
________________________________________
________________________________________
(Template instruction: Provide a full and detailed description of the duties of the position as they will appear on ETA Form 9089, Section H. The duties described herein must reflect the actual requirements of the job opportunity and must not be tailored to match the specific qualifications, experience, or background of any particular individual, including the foreign national beneficiary. Duties should be described in sufficient detail to enable a prospective applicant to evaluate whether he or she is qualified for the position. Where possible, indicate the approximate percentage of time devoted to each major duty category.)
3.4 Minimum Education Requirements
Minimum Degree Level Required: ________
Required Field(s) of Study: ________
(Template instruction: State the minimum educational requirement for the position exactly as it will appear on ETA Form 9089. For positions classified under the EB-2 Advanced Degree Professional category, the minimum educational requirement must be at least a U.S. Master's degree or its foreign equivalent in a relevant field of study, or alternatively, a U.S. Bachelor's degree or its foreign equivalent in a relevant field of study plus five (5) years of progressive post-baccalaureate experience in the specialty. The educational requirement stated must reflect the employer's actual minimum requirement for the position and must be consistent with what is customary in the industry for the occupation in question. Any alternative acceptable degree fields must also be listed.)
3.5 Minimum Experience Requirements
Minimum Years of Experience Required: ________
Description of Required Experience: ________
________________________________________
________________________________________
(Template instruction: State the minimum number of years and type of professional experience required for the position. Experience requirements must reflect the employer's actual minimum requirements for the position and must not exceed what is customary and standard for the occupation within the industry. If the experience requirement includes specialized or progressive experience in a particular area, describe that area with specificity. Note that under 20 CFR §656.17(i), experience gained with the sponsoring employer may be credited toward the minimum requirements only under certain limited conditions — consult with Calderwood & Harkness LLP before specifying any experience requirement that the beneficiary satisfies through employment with Lumos Analytics Inc.)
3.6 Special Skills, Certifications, or Other Requirements
Special Skills, Professional Certifications, Licenses, or Other Requirements:
________________________________________
________________________________________
________________________________________
________________________________________
(Template instruction: List any special skills, professional certifications, licenses, language requirements, or other requirements for the position. Each special requirement must be justified by business necessity and must reflect the actual minimum requirements of the position as it exists within the employer's organization. Special requirements must not be unduly restrictive and must not be designed to preclude otherwise qualified U.S. workers from consideration. Examples of special requirements for the Lumos cases may include, but are not limited to: CISSP (Certified Information Systems Security Professional) certification for the Director, Information Security & Compliance position; demonstrated experience with specific technologies such as Apache Kafka, Kubernetes, TensorFlow, or PyTorch; a record of peer-reviewed publications in relevant scientific or technical journals; and/or experience with specific regulatory frameworks such as the Fair Credit Reporting Act (FCRA), the Equal Credit Opportunity Act (ECOA), the Gramm-Leach-Bliley Act (GLBA), or SOC 2 compliance standards. Each special requirement listed herein must be documented with a business necessity justification and retained in the PERM audit file.)
3.7 Offered Salary
Annual Salary Offered: $________ per year
(Template instruction: The offered salary must meet or exceed the prevailing wage as determined by the National Prevailing Wage Center (NPWC) for the applicable SOC code and geographic area. The prevailing wage area for the Lumos Analytics Inc. worksite at 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303 falls within the San Jose-Sunnyvale-Santa Clara, CA Metropolitan Statistical Area (MSA), Office of Employment Statistics (OES) Area Code 41940. The offered wage must equal or exceed the applicable prevailing wage at the wage level assigned by the NPWC on the approved prevailing wage determination. Failure to offer a wage at or above the prevailing wage will result in denial of the PERM application. The employer must be able to demonstrate the ability to pay the offered wage as of the PERM priority date.)
3.8 Work Schedule and Conditions
Hours: Full-time position, minimum forty (40) hours per week.
Supervisory Responsibilities: ________
(Indicate Yes or No. If yes, describe the nature of supervisory responsibilities, including the number and types of direct reports.)
Travel Requirements: ________
(Indicate the approximate percentage of travel required, if any, and whether travel is domestic, international, or both.)
Other Conditions of Employment: ________
(Include any other material conditions of employment, such as on-call requirements, shift work, physical demands, or security clearance requirements.)
3.9 Location of Employment
Primary Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303
The offered position is based at the employer's principal office located at the address stated above. The foreign national employee will perform the majority of his or her job duties at this worksite. Any requirement for travel to client sites, other Lumos Analytics Inc. offices, or conference locations is described in Section 3.8 above.
Section 4: Filing Information
Immigrant Visa Classification: EB-2 — Employment-Based Second Preference (Advanced Degree Professional), pursuant to Section 203(b)(2) of the Immigration and Nationality Act, 8 U.S.C. §1153(b)(2)
Federal Agency Receiving Application: U.S. Department of Labor, Employment and Training Administration, Office of Foreign Labor Certification (OFLC), Atlanta National Processing Center
Application Type: ETA Form 9089 — Application for Permanent Employment Certification
PERM Case Number (if assigned): ________
Date of PERM Filing (or Anticipated Filing Date): ________
(Template instruction: If the PERM application has not yet been filed with the Department of Labor at the time this notice is posted at the worksite, state the anticipated filing date. If the PERM application has already been filed, state the actual filing date and the assigned PERM case number. The case number is typically in the format A-XXXXX-XXXXX. Note that under 20 CFR §656.17(f), the PERM application must not be filed earlier than 30 days after the date the SWA job order is placed and not later than 180 days after the date recruitment has been completed. Coordinate filing dates with Calderwood & Harkness LLP.)
Section 5: How to Apply / Employee Notification
Any person may apply for this position. U.S. workers — including U.S. citizens, U.S. nationals, lawful permanent residents, asylees, and refugees — who believe they are qualified for this position are encouraged to apply. There is no requirement that applicants currently be employed by Lumos Analytics Inc. in order to be considered for the position described in this notice.
How to Submit an Application:
Applications should be submitted in writing to the following contact at Lumos Analytics Inc.:
________________________________________
(Contact Name)
________________________________________
(Title)
Lumos Analytics Inc. 2240 Embarcadero Way, Suite 600 Palo Alto, CA 94303
Email submissions may be sent to: ________
Applications must include a current resume or curriculum vitae (CV) detailing the applicant's education, professional experience, certifications, and other qualifications relevant to the minimum requirements described in Section 3 of this notice. Applicants are encouraged to provide sufficient detail regarding their qualifications to permit a thorough evaluation of their candidacy.
Evaluation of Applications: Applications will be reviewed and evaluated solely based on the minimum education, experience, and other requirements stated in this posting. All applicants will be assessed using the same lawful, job-related criteria without regard to any characteristic protected under applicable federal, state, or local law. No applicant will be given preference or subjected to disfavor based on any factor other than his or her qualifications as measured against the stated requirements of the position.
No Obligation to Hire: This posting does not obligate Lumos Analytics Inc. to hire any applicant and does not create an employment contract or a promise of employment. The employer will consider all qualified applicants in accordance with applicable U.S. Department of Labor regulations governing the PERM labor certification process, including 20 CFR Part 656. Lumos Analytics Inc. reserves all rights afforded to employers under applicable law regarding hiring decisions for this position.
Section 6: Posting Period and Compliance
Date Posted: ________
Date Removed (10th Consecutive Business Day): ________
Posting Location(s):
________________________________________
(Describe the specific conspicuous location(s) at 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303 where this notice is physically displayed. The location(s) must be areas where notices to employees are customarily posted and where the notice is reasonably likely to be seen by all employees at the worksite. Suitable locations include, but are not limited to: employee break room bulletin board, main lobby entrance bulletin board, HR department bulletin board, or common area adjacent to the elevator bank on the 6th floor. If the notice is posted in multiple locations, list each location.)
This notice must remain posted for a minimum of ten (10) consecutive business days in accordance with 20 CFR §656.10(d). Business days do not include weekends or federal holidays. The notice must not be removed, obscured, or relocated during the mandatory posting period. If the notice is inadvertently removed or becomes illegible during the posting period, it must be reposted and the 10-business-day count must restart from the date of reposting.
Compliance Certification.  I certify that this notice was posted in a conspicuous location at the worksite described above on the date indicated and was removed on the date indicated, having been posted for at least ten (10) consecutive business days in compliance with the requirements of 20 CFR §656.10(d). I further certify that the notice was posted in a location where it was reasonably accessible to and could be seen by all employees at the worksite, and that the notice was not removed, obscured, defaced, or relocated at any time during the posting period.
Signature of Authorized Representative: ________
Printed Name: ________
Title: ________
Date: ________
Section 7: Non-Discrimination Statement
Lumos Analytics Inc. is an equal opportunity employer. This notice is posted pursuant to federal regulatory requirements in connection with the PERM labor certification process under 20 CFR Part 656 and does not reflect any preference for or against any applicant on the basis of national origin, citizenship status, or immigration status, except as required or permitted by applicable law.
All qualified applicants will receive consideration for the position described in this notice without regard to race, color, religion, sex (including pregnancy, childbirth, and related medical conditions), sexual orientation, gender identity, gender expression, national origin, ancestry, age, disability, genetic information, veteran status, military service, marital status, or any other characteristic protected by applicable federal, state, or local law, including but not limited to the California Fair Employment and Housing Act (Cal. Gov. Code §12900 et seq.) and Title VII of the Civil Rights Act of 1964, as amended (42 U.S.C. §2000e et seq.).
Section 8: Additional Regulatory Notices
The filing of an application for permanent employment certification with the U.S. Department of Labor does not constitute a guarantee of employment to any applicant, nor does it guarantee that the application will be approved by the Department of Labor. The PERM labor certification process is a regulatory procedure through which the Department of Labor evaluates whether there are sufficient qualified U.S. workers available for the position offered and whether the employment of a foreign national in the position would adversely affect the wages and working conditions of similarly employed U.S. workers.
Questions regarding the PERM labor certification process, including the regulatory requirements governing the filing of ETA Form 9089 and the recruitment procedures applicable to professional occupations, may be directed to the U.S. Department of Labor, Office of Foreign Labor Certification. General information about the PERM program is available on the Department of Labor's Foreign Labor Certification website at https://www.dol.gov/agencies/eta/foreign-labor.
The employer's immigration counsel for this matter is:
Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104 Matter No. 1008-00004
All inquiries from prospective applicants regarding the position itself should be directed to the employer contact identified in Section 1 of this notice, not to the employer's immigration counsel.
— FOR INTERNAL USE ONLY —
INSTRUCTIONS TO LUMOS ANALYTICS INC. HR TEAM
DO NOT POST THIS PAGE
To: Janelle Kwon, HR Manager, Lumos Analytics Inc. From: Tiffany Rosenthal, Calderwood & Harkness LLP Re: Completion and Posting Instructions — PERM 10-Day Worksite Notice Template Matter No.: 1008-00004
General Instructions:
This template must be completed separately for each of the four beneficiary positions for which PERM labor certification applications are being filed by Lumos Analytics Inc. Each completed posting must contain the specific job title, SOC code, job duties, minimum requirements, and offered salary applicable to the individual position. Under no circumstances should a single posting be used to cover more than one position.
The four positions requiring separate postings are as follows:
IMPORTANT — Beneficiary Name Confidentiality: The beneficiary's name must NOT appear anywhere on the posted notice. The worksite posting is required to describe the job opportunity and the terms and conditions of employment; it is not required to identify, and must not identify, the foreign national employee being sponsored. The inclusion of the beneficiary's name on the posted notice could compromise the integrity of the recruitment process and may raise issues in the event of a PERM audit. All four postings should be reviewed carefully before posting to confirm that the beneficiary's name does not appear.
Posting Schedule:
•  Campaign 1 (Rajan Mehta — VP, Engineering and Lina Varga — Senior Director, Data Science): The worksite postings for these two positions are to be coordinated with the broader recruitment campaign commencing on October 9, 2023. The notices should be posted on or before October 9, 2023 and should remain posted for a minimum of 10 consecutive business days. Assuming posting on October 9, 2023 (Monday), and excluding weekends and the Columbus Day federal holiday (October 9, 2023), the earliest permissible removal date should be calculated accordingly. Please consult with Calderwood & Harkness LLP to confirm the exact removal date.
•  Campaign 2 (Tomás Aguilar-Reyes — VP, Product and Yumiko Tanaka — Director, Information Security): The worksite postings for these two positions are to be coordinated with the broader recruitment campaign commencing on October 23, 2023. The notices should be posted on or before October 23, 2023 and should remain posted for a minimum of 10 consecutive business days. Please consult with Calderwood & Harkness LLP to confirm the exact removal date.
Post-Removal Documentation Requirements:
Upon removal of each posting at the conclusion of the 10-business-day posting period, the following steps must be completed:
1.  The Compliance Certification in Section 6 of each posting must be completed and signed by an authorized representative of Lumos Analytics Inc. (Janelle Kwon or another authorized officer or manager).
2.  A photograph or high-resolution scan of each posted notice in situ (i.e., as it appeared while physically posted at the worksite) must be taken prior to removal. The photograph should clearly show (a) the full text of the notice, and (b) the surrounding area sufficient to demonstrate that the notice was posted in a conspicuous location at the worksite.
3.  The completed and signed certification, together with the photograph or scan, must be forwarded promptly to:
(a) Janelle Kwon, HR Manager, Lumos Analytics Inc. (internal retention copy); and
(b) Derek Okonkwo, Associate, Calderwood & Harkness LLP, 555 California Street, 32nd Floor, San Francisco, CA 94104 (email: dokonkwo@calderwoodharkness.com) — for inclusion in the PERM audit file.
Document Retention:
All recruitment documentation, including each completed worksite posting, the signed compliance certification, and the photograph or scan of the posted notice, must be retained for a minimum of five (5) years from the date of filing the PERM application or from the date the recruitment was conducted, whichever is later. This retention requirement is mandated by 20 CFR §656.10(f) and applies regardless of whether the PERM application is approved, denied, or withdrawn. Lumos Analytics Inc. should maintain these records in a secure and accessible location, organized by beneficiary name and PERM case number.
Coordination with Other Recruitment Steps:
Please note that the internal worksite posting is only one of several mandatory recruitment steps required for PERM applications filed for professional occupations. Broadgate Compliance Services LLC (contact: Gerald Fitzmorris, 1414 K Street NW, Suite 730, Washington, DC 20005) has been retained to handle the placement of the following additional mandatory recruitment advertisements on behalf of Lumos Analytics Inc.:
•  Two print advertisements in a newspaper of general circulation (Sunday edition of the San Jose Mercury News);
•  State Workforce Agency (SWA) job order filed with the California Employment Development Department (EDD);
•  Online posting on a professional journal or trade publication website relevant to the occupation; and
•  Additional recruitment steps as required under 20 CFR §656.17(e)(1) for professional occupations (three of ten additional steps).
The internal worksite posting described in this template is the sole responsibility of the Lumos Analytics Inc. HR team and is not being handled by Broadgate Compliance Services LLC. It is critical that the posting be completed, displayed, and documented in accordance with the instructions above, as the worksite posting is frequently a focus of Department of Labor audits of PERM applications.
Questions:
Any questions regarding the completion of this template, the calculation of posting dates, the documentation of the posting period, or any other aspect of the PERM recruitment process should be directed to:
Tiffany Rosenthal, Partner Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104
Phone: (415) 555-0138
Email: trosenthal@calderwoodharkness.com
Derek Okonkwo, Associate Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104
Phone: (415) 555-0142
Email: dokonkwo@calderwoodharkness.com
CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED — ATTORNEY WORK PRODUCT
This template and the instructions contained herein have been prepared by Calderwood & Harkness LLP for the exclusive use of Lumos Analytics Inc. in connection with the PERM labor certification applications identified above. This document is protected by the attorney-client privilege and the attorney work product doctrine. Any unauthorized disclosure, distribution, or reproduction of this document is strictly prohibited. Receipt of this document by any person other than the intended recipient does not constitute a waiver of any applicable privilege.
© 2023 Calderwood & Harkness LLP. All rights reserved.
No. | Job Title | Beneficiary | SOC Code | SOC Title | Campaign
1 | VP, Engineering — Core Platform | Rajan Mehta | 15-1252 | Software Developers | Campaign 1
2 | Senior Director, Data Science & Machine Learning | Lina Varga | 15-2051 | Data Scientists | Campaign 1
3 | VP, Product — Fintech Solutions | Tomás Aguilar-Reyes | 11-2021 | Marketing Managers | Campaign 2
4 | Director, Information Security & Compliance | Yumiko Tanaka | 15-1212 | Information Security Analysts | Campaign 2

NOTICE OF FILING — PERM LABOR CERTIFICATION APPLICATION

INSTRUCTIONS TO LUMOS ANALYTICS INC. HR TEAM

DO NOT POST THIS PAGE

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