Perfect Attendance Question

We give two hours of Well Time (comp)to employees who have perfect attendance in a month. If they have perfect attendance for the year, it would of course add up to three extra days off for them in a year.

Question: Would this be considered a perfect attendance award that would be subject to the FMLA qualifing event exception? In other words, would we have to give the two hours to someone who was off on FMLA, STD or WC?

Any help?

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