MODEL AFFIRMATIVE ACTION PLAN
GOVERNMENT CONTRACTORS
It is the policy of [Name of Company] ("Company") to promote equal employment opportunities through a positive continuing program of specific practices designed to ensure the full realization of equal employment opportunities without regard to race, color, religion, sex, or national origin.
To implement these policies, the Company [will continue to] will:
Recruit, hire, train, and promote persons in all job classifications without regard to race, color, religion, sex, or national origin.
Base decisions on employment so as to further the principle of equal employment opportunity.
Insure that all personnel actions, including, but not limited to, compensation, benefits, transfers, layoffs, return from layoffs, company sponsored training, education, and tuition assistance, and social and recreational programs, are administered without regard to race, color, religion, sex, or national origin.
Insure that promotion decisions are in accord with principles of equal employment opportunity by imposing only valid requirements for promotion.
Equal employment opportunity is not only the law, but it is a principle of our Company's operation. I expect each employee to cooperate to achieve this goal and I personally stand behind this principle.
Chief Executive Officer
[This policy statement should be signed, reaffirmed, and reissued annually.]
Responsibility for the implementation of all affirmative action programs is placed in an Equal Employment Opportunity Coordinator ("Coordinator"). [Name], our [Position], has been appointed Coordinator. His name [appears and] will appear on all internal and external communications regarding the Company's affirmative action programs.
As Coordinator, [name] [has been and] will be given necessary top management support and staffing to execute his assignment.
The Coordinator has the responsibility to:
Develop policy statements, affirmative action programs, internal and external communication techniques, and monitoring systems.
Identify problem areas.
Assist line management in arriving at solutions to problems.
Design and implement an audit and reporting system that will measure the effectiveness of the affirmative action program, indicate the need for remedial action, if any, and determine whether the contractor's goals have been attained.
Serve as liaison between the Company and enforcement agencies.
Serve as liaison with private and public employment services for the recruiting of minority groups and women, as well as minority and women's organizations and community action groups concerned with employment opportunities for minorities and women.
Keep management informed of the latest developments in the entire equal employment opportunity area.
Assist in identifying problem areas and establishing local goals and objectives.
Become active with local minority and women's organizations, community action groups, and community service programs. [List them where feasible.]
Periodically audit training programs and hiring and promotion patterns to remove impediments to the attainment of goals and objectives. [How often? Consider quarterly at the beginning, but semiannually thereafter.]
Conduct regular discussions with supervisors and employees to insure implementation of the affirmative action program.
Review the qualifications of all employees to ensure that minorities and women have full opportunities for transfers and promotions.
Provide career counseling for all employees.
Periodically audit each location for compliance, insuring that:
Posters are properly displayed.
No Company facilities, including Company housing, are segregated in anyway.
Minority and female employees are encouraged to participate in all Company sponsored activities, including, but not limited to, training. [List any other activities.
Advise supervisors that their work performance is being evaluated on the basis of their equal employment opportunity efforts and results, as well as other criteria, and that they must take action to prevent harassment of employees placed through affirmative action efforts.
The Company's policy concerning its affirmative action program [has been and] will be disseminated internally as follows:
The policy [is and] will be included in all Company personnel policy manuals. [Specify.]
The policy and our accomplishments [have been and] will be publicized in Company publications, including the annual report, and any newspaper, magazine, or other medium that the Company uses. [Specify.]
Special meetings [have been and] will be held at least once each year with executive, management, and supervisory personnel. Each meeting [has emphasized and] will emphasize the importance of the policy, explaining its intent and stressing each supervisor's individual responsibility for its effective implementation. (Keep minutes.)
Special meetings [have been and] will be scheduled at least once each year with all other employees to discuss the policy and explain individual employee responsibilities. [Specify when and where, and keep minutes.]
The policy [has been and] will be thoroughly discussed in all employee orientation and management training programs. [Specify.]
Union officials [have been and] will be informed of the policy, and their cooperation [has been and] will be requested.
Nondiscrimination clauses [have been and] will be included in all union agreements, and all contractual provisions [have been and] will be reviewed to ensure that they are nondiscriminatory.
The affirmative action program and any progress reports regarding the employment of females and minorities [have been and] will be publicized in Company publications. [Specify.]
The policy [has been and] will be posted on employee bulletin boards. [Specify.]
When employees are featured in product or consumer advertising, employee handbooks, or similar publications, pictures of both minority and nonminority men and women (have been and) will be included.
The existence of the Company's affirmative action program [has been and] will be communicated to employees by notices on the bulletin board. A copy of the affirmative action program [has been and] will be available at the office of the Coordinator [or Personnel Department], so that employees shall be able to avail themselves of its benefits.
External dissemination of the Company's policy [has been and] will be accomplished as follows:
The Company (has informed and) will inform, verbally and in writing, all recruiting sources of the Company policy, requesting these sources to actively recruit and refer minorities and women for all positions listed.
The following equal opportunity clause (has been and) will be inserted in each purchase order, lease, and contract with suppliers, vendors, or subcontractors:
The subcontractor or vendor shall not discriminate against any employee or applicant for employment because of race, color, religion, sex, or national origin. The subcontractor or vendor shall take affirmative action to ensure that applicants are employed, and that employees are treated during employment, without regard to their race, color, religion, sex, or national origin. Such action shall include, but not be limited to:
employment, upgrading, demotion, or transfer, recruitment or recruitment advertising, layoff or termination, rates of pay or other forms of compensation, and selection for training, including apprenticeship. The subcontractor or vendor agrees to post, in conspicuous places available to employees and applicants for employment, notices to be provided by the contracting officer, setting forth the provisions of this nondiscrimination clause.
The subcontractor or vendor shall, in all solicitations or advertisements for employees placed by it or on its behalf, state that all qualified applicants will receive consideration for employment without regard to race, color, religion, sex, or national origin.
The subcontractor or vendor shall send to each labor union or representative of workers with which it has a collective bargaining agreement or other contract or understanding, a notice, to be provided by the agency-contracting officer, advising the labor union or workers' representative of the subcontractor's or vendor's commitments under Section 202 of Executive Order 11246 of September 24, 1965, and shall post copies of the notice in conspicuous places available to employees and applicants for employment.
The subcontractor or vendor shall comply with all the provisions of Executive Order 11246 of September 24, 1965, and of the rules, regulations, and relevant orders of the Secretary of Labor.
The subcontractor or vendor shall furnish all the information and reports required by Executive Order 11246 of September 24,1965, and by the rules, regulations, and orders of the Secretary of Labor pursuant thereto, and will permit access to its books, records, and accounts by the contracting agency and the Secretary of Labor for purposes of investigation to ascertain its compliance with all such rules, regulations and orders.
In the event the subcontractor or vendor does not comply with the nondiscrimination clauses of this contract or with any rule, regulation, or order of the Secretary of Labor, this subcontract or purchase order may be cancelled terminated, or suspended in whole or in part, and the subcontractor or vendor may be declared ineligible for further government contracts in accordance with the procedures authorized in Executive Order 11246 of September 24 1965, and other sanctions may b imposed and remedies invoked, a provided in Executive Order 11241 of September 24, 1965, by rule regulation, or order of the Secretary of Labor, or by law.
The subcontractor or vendor shall include the provisions of these paragraphs in every subcontract or purchase order, unless exempted by the rules, regulations, or orders of the Secretary of Labor issued pursuant to Section 204 of Executive Order 11246 of September 24, 1965, so that those provisions shall be binding upon each subcontractor or vendor. The subcontractor or vendor shall take such action with respect to any subcontract or purchase order as the contracting agency may direct as a means of enforcing these provisions, including sanctions for noncompliance, provided, however, that in the event the subcontractor or vendor becomes involved in, or is threatened with, litigation with a subcontractor or vendor as a result of a direction by the contracting agency, the subcontractor or vendor may request the United States to enter into litigation to protect the interests of the United States.
When pictures of employees appear in consumer or help-wanted advertising, both minority and non-minority men and women [have been and] will be shown.
The Company [has notified and] will notify the following minority and women's organizations, community leaders, secondary schools, and colleges of Company policy. [Specify.]
The Company [has communicated and] will communicate to prospective employees the existence of the Company's affirmative action program and make available such elements of the program as will enable prospective employees to know and avail themselves of its benefits. (Specify. Consider a statement on applications or a sign where applicants apply. A copy should be available at the personnel office.)
Notification of Company policy [has been and] will be sent to all subcontractors, vendors, and suppliers, requesting appropriate action on their part.
The following letter [has been and] will be sent to each subcontractor, supplier, and vendor:
Ms./Mr.:
As your firm is well aware, our Company is an equal opportunity employer. Pursuant to Executive Order 11246, as amended, you are advised that under the provisions of government contracts and in accordance with the Executive Order, contractors and subcontractors are obliged to take affirmative action to provide equal employment opportunity without regard to race, creed, color, national origin, or sex. We expect to see our commitment to equal opportunity employment reflected in the racial and sexual composition of your firm's workforce and urge a vigorous affirmative action program to overcome underutilization.
The attached form will need to be completed and returned to us at your earliest convenience. Thank you.
Sincerely,
Affirmative Action Program Acknowledgment by Supplier, Subcontractor, or Vendor
Name
Street Address
Telephone
City State
Please indicate whether your firm has already developed a written affirmative action program because of previously held contracts or subcontracts subject to the Equal Employment Opportunity Clause of Executive Order 1 1 246.
Yes __ No __
We acknowledge receipt of the notice of the requirement to undertake affirmative action to overcome any underutilization.
Signature
Title
Date
Please return form to:
GOALS AND TIMETABLES
The goals and timetables developed by the contractor should be attainable in terms of the contractor's analysis of its deficiencies and its entire affirmative action program Thus, in establishing the size of its goals and the length of its timetables, the contractor should consider the results which could reasonably be expected from its putting forth every good faith effort to make its overall affirmative action program work. In determining levels of goals, the contractor should consider at least the factors listed below.
When a comparison of the availability of minorities and women for job groups to their percentages in the Company's job group population indicates [indicated] an underutilization, the Company [has and] will set a goal and a timetable to reach that goal.
All goals and timetables set [have been and] will be attainable.
Goals should reflect the results that reasonably could be expected from putting forth every good faith effort to make the Company's affirmative action program work.
Each year the Coordinator [has prepared and] will prepare a listing of each job title as set forth on our payroll records or collective bargaining agreements.
A separate list by job title within each department or work unit, ranked from the lowest paid to the highest paid, [has been and] will be prepared.
For each job title, the listing [has included and] will include the total number of
incumbents.
Male incumbents.
Female incumbents.
Male and female minority incumbents:
Blacks.
Hispanics.
American-Indians.
Asians and Pacific Islanders.
[Instead of using names, employ some sort of code, like social security or employee numbers.]
Each year, the Coordinator [has prepared and] will prepare an analysis of job groupings, with all job titles with similar content, wage rates, and opportunities for advancement grouped together.
Each year for each job group, the Coordinator [has done and] will do an analysis of the following factors for minorities and women:
Minorities
The minority population of the labor area surrounding the facility.
The size of the minority unemployment force in the labor area surrounding the facility.
The percentage of the minority work force as compared with the total work force in the immediate labor area.
The general availability of minorities having requisite skills in the immediate labor area and in the recruitment area.
The availability of promotable and transferable minorities within the Company's organization.
The existence of training institutions capable of training persons in the requisite skills.
The degree of training the Company is reasonably able to undertake as a means of making all job classes available to minorities.
Women
The availability of women seeking employment in the labor or recruitment area.
The size of the female unemployment force in the labor area surrounding the facility.
The percentage of the female work force as compared with the total work force in the immediate labor area.
The general availability of women having requisite skills in the immediate labor area and in the recruitment area.
The availability of promotable and transferable female employees within the Company's organization.
The existence of training institutions capable of training persons in the requisite skills.
The degree of training the Company is reasonably able to undertake as a means of making all job classes available to women.
A statistical analysis of the work force by minority group status and sex [has been and] will be made at least annually. [An employer may want to do this analysis semiannually to discover any problem area in time to remedy it before the annual review. In addition, the annual review may be scheduled for the same time as the preparation of the EEO- I forms, i.e., in February or March of each year.]
The Coordinator [has reviewed and] will review the composition of the applicant flow by minority group status and sex at least annually. The Company [has maintained and] will maintain a register at the point of receiving applications for employment, indicating the name of the applicant, the minority group status (Black, Hispanic, American Indian, Asian, or Pacific Islander) and sex of the applicant, and the job applied for. The contents of this register [have been and] will be summarized at least every six months according to the positions for which employment applications were received, and the applicant flow [has been and] will be compared with the availability analysis figures. An analysis [has been and] will be made to see whether any variations are due to mistakes in the availability analysis, failure to maximize minority and female applicant flow, or some other cause. (There are a variety of ways to maintain records of applicant flow. Some companies use a chart maintained by the receptionist in the personnel area. Identification of minorities is made visually. Other companies ask applicants to complete either a special form that is kept separately or a perforated portion of the application form that is separated. The important point is to keep the information about minority group status and sex separate from the application document.)
The Company has analyzed all of its position descriptions, position titles, worker specifications, application forms, interview procedures, tests, testing procedures, referral procedures, final selection processes, and similar matters to determine whether they are interfering with the hiring and advancement of qualified minorities and women. At present, no problems exist. [Prepare and keep on File detailed narrative descriptions of these procedures, together with explanations why they do not raise any problems.]
The Company has analyzed its transfer and promotion practices and found that they present no problems. Transfer and promotion practices will continue to be analyzed annually. [To be sure that minority group members and women are not kept from promotion because of racial or sexual stereotypes, the Company must have a mechanism that enables employees who seek promotion or transfer to identify their wishes, so that they can be considered on the basis of their qualifications at the time an opening occurs. One alternative is a system of posting job openings that will give all employees an equal opportunity to apply. Another possibility is to talk individually with the employees and have them supply a list of positions for which they may qualify and to which they wish to be promoted or transferred. If the second procedure is utilized, the inventory of skills and interests should be consulted prior to filling any position.)
All Company facilities, sponsored recreation and social events, and special programs such as educational assistance [are and] will be available to all Company employees without regard to minority group status or sex.
Seniority practices and seniority provisions in union contracts [if any] have been reviewed. Present seniority practices are based upon length of service and not upon minority group status or sex. [Special attention must be given to seniority systems that perpetuate the results of past discrimination. If there has been, or is likely to be, a finding of past discrimination, it may be necessary to bypass even a bona fide seniority system.]
The Company's apprenticeship programs [if any have been reviewed and they do not discriminate against minority group members or women. They will be reviewed annually, and the results will be reflected in the availability analysis. [Describe the programs.]
The Company has reviewed its training programs, both formal and informal, and found them to be nondiscriminatory. These programs will be analyzed annually. [Describe the programs.]
The Company has ascertained that the attitude of its work force is conducive to the principles of affirmative action and to nondiscriminatory treatment for all employees regardless of minority group status or sex.
The Company has ascertained that all technical phases of compliance have been achieved. The following posters are posted at the following locations. [List the posters. They are available from the Equal Employment Opportunity Commission, the Department of Labor, and state labor and equal rights agencies.] The following notification has been sent to all labor unions, and the following clauses are contained in the collective bargaining agreements. [List the notification and clauses]. Notification on the form contained in Exhibit A hereto has been made to all subcontractors, and the Equal Opportunity Clause is made a part of the Company's requisition or purchase order form. [The language of the notification to subcontractors and the Equal Opportunity Clause was stated earlier.] Applications for employment are retained for a period of one year.
No underutilization of minorities or women was found except in the following areas: [List them.] Goals and timetables have been set to correct these problem areas as follows: [List them.]
No lateral or vertical movement of minority or female employees is occurring at a rate significantly less than the movement of nonminorities and males, except as follows: [List and explain or set forth the corrective action.]
Selection ratios for women and minorities are within the guidelines of the Uniform Guidelines on Employment Selection Procedures [Regulations ¤60-3] with the exception of: [List and explain or set forth corrective action.]
Applications and related pre-employment forms have been reviewed and are in compliance with federal legislation.
Position descriptions have been reviewed and accurately reflect the function and duties of the jobs described.
The Company uses the following [number] formal tests: [List them.] All are valid pursuant to the Uniform Guidelines on Employee Selection Procedures [Regulations ¤60-3] [either because they do not have an adverse impact on minorities or women or have been validated].
Where tests [have been or] are being validated, the validation studies follow the Uniform Guidelines on Employee Selection Procedures [Regulations ¤60-3].
An analysis of referral ratios did not indicate that a significantly higher percentage of minorities or women are being rejected as compared to nonminorities or men.
Neither minorities nor women are excluded from, or are not participating in, Company sponsored activities or programs.
De facto segregation does not exist at any Company facility.
Seniority provisions do not contribute to overt or inadvertent discrimination.
Company equal employment opportunity policy is supported by managers, supervisors, and employees.
Minorities and women are not significantly underrepresented in training or career improvement programs.
Formal techniques have been established to evaluate the effectiveness of equal employment opportunity programs. [List them.]
Lack of access to suitable housing does not inhibit recruitment efforts and employment of qualified minorities.
There is no lack of suitable public or private transportation to the workplace to inhibit minority employment. [Alternatively, explain the situation and what you have done or could do about it.]
Labor unions and subcontractors have been notified of their responsibilities.
Purchase orders contain the EEO clause.
Posters are on display.
[While most of the following materials are really included in earlier sections, compliance officials prefer them separately stated.]
Policy and practices.
It is the policy of the Company to provide equal employment opportunities to qualified individuals regardless of sex through a positive program designed to employ, and advance the employment of, individuals of both sexes. This policy covers all personnel practices, including hiring, upgrading, demotion or transfer, recruitment or recruitment advertising, layoff or termination, rates of pay or other forms of compensation, and selection for training. The Company will [will continue to] utilize the following measures to effectuate this policy:
All written personnel policies, including the Company personnel manual, [indicate and] will indicate that there shall be no discrimination against employees because of sex.
Written agreements with bargaining representatives of employees concerning conditions of employment [are not and] shall not be inconsistent with this affirmative action program concerning sex discrimination.
Employees of both sexes [have had and] will have an equal opportunity to any available job that he or she is qualified to perform, unless sex is a bona fide occupational qualification. [In most government contract work, only in limited instances can valid reasons exist for excluding all men or all women from a particular job.]
The Company [does not and] will not make any distinction based upon sex in employment opportunities, wages, hours, or other conditions of employment.
The Company [does not and] will not discriminate against individuals on the basis of sex in its insurance, pension, and welfare programs and other similar fringe benefits.
The Company [does not and] will not discriminate against any individual on the basis of marital status.
The Company [does not and) will not deny employment to any individual because he or she has young children.
The Company [does not and will not terminate an employee of one sex in a particular job classification upon reaching a certain age unless the same rule is applicable to members of the other sex.
Appropriate physical facilities and restrooms [are and] will be available to individuals of both sexes.
The Company [does not and will not refuse to hire men or women or deny them a particular job because no restroom or associated facilities are available for them, unless construction of the facilities would be unreasonable due to such reasons as excessive expense or lack of space. [A single restroom with a switchable sign can serve both men and women.]
The Company [does not and] will not deny, in reliance upon any state protective law, any female employee the right to any job that she is qualified to perform.
The Company [does not and] will not penalize any woman in her condition of employment because she requires time away from work for childbearing.
The Company [does not and) will not under its leave-of-absence policy refuse to grant an eligible female employee a leave of absence for the purpose of childbearing for a reasonable period of time. The conditions applicable to her leave other than the length thereof and to her return to employment shall accord with the Company's leave policy for men. [Where the Company has no leave policy for men substitute: Childbearing [has been and] will be considered by the Company to be a justification for a leave of absence for a female employee for a reasonable period of time. Following childbirth, when the female employee signifies her intent to return to work within a reasonable time, she shall be reinstated to her original job or to a. position of like status and pay, without loss of any service credits.]
The Company [does not and] will not specify any differences for male and female employees on the basis of sex in either mandatory or optional retirement age.
Seniority System. The seniority policy of the Company [has not and] will not be based solely upon sex.
The Company [has and] will have the following policy concerning wages:
The Company's wage schedules [are not and] will not be related to, or based upon, the sex of its employees.
The Company [does not and] will not discriminatorily restrict one sex to certain job classifications.
Recruitment and advertisement. The Company [has taken and] shall take each of the following steps:
Persons [have been and] will be recruited for all jobs without regard to sex, unless sex is a bona fide occupational qualification.
Advertisements for employment in newspapers and other media [have not and] will not express a sex preference unless sex is a bona fide occupational qualification for the particular job advertised, and no advertisement will be placed in a newspaper in a column headed "Male" or "Female."
Affirmative action. [This paragraph is required when there are jobs or job groups devoid of women or in which they are severely underutilized, but it is always useful generally.]
The Company [has taken and] will take affirmative action to recruit women to apply for jobs. To implement this policy, itineraries of recruiting trips [have included and will include women's colleges in which graduates with skills desired by the Company can be found, and advertisements [have and] will indicate that women would be considered equally with men for jobs. [List colleges and specify advertisements.]
The Company [has included and] will include women candidates in management training programs.
The Company does not and] will not make distinctions based on sex in any other training programs. Both sexes [have and] shall have equal access to all training programs. [Show how equal access has been or will be provided.]
[Here again, most of the following materials are included in earlier sections, but compliance officials prefer to see them stated separately.]
Equal employment policy.
The Company [does not and] will not discriminate against employees or applicants for employment because of religion or national origin. The policy of the Company is to provide equal employment opportunity to qualified individuals without regard to religion or national origin through a positive, continuing affirmative action program designed to insure that applicants are employed, and employees treated during employment, without regard to their religion or national origin. This policy covers all personnel practices, including, but not limited to. employment, upgrading, demotion or transfer, recruitment or recruitment advertising, layoff or termination, rates of pay or other forms of compensation, and selection for training, including apprenticeship. The Company [has utilized and] will utilize the following measures to promote equal opportunity without regard to religion or national origin:
The Company has reviewed its employment practices and determined that members of various religious or ethnic groups are receiving fair consideration for job opportunities, with special attention toward executive and middle management level positions.
The Company has undertaken and] will undertake the following outreach recruitment activities: [While the following steps are optional unless the Company has found a specific problem area, the language of the regulations seems to call for some steps to be taken.]
The Company [has communicated and] will communicate internally its obligation and policy to provide equal employment opportunity without regard to religion or national origin. Specifically, the Company [has undertaken and] will undertake the following steps:
Include the policy in personnel policy manuals and Company publications, including the annual report and newspaper, magazine, or other media. [Specify].
Discuss the policy in employee orientation and management training programs. Keep minutes].
Notify union officials of the policy and request their cooperation.
Include nondiscrimination clauses in union agreements and review all contractual provisions to ensure that they are nondiscriminatory.
Publish in Company publications information concerning the affirmative action program.
Post the policy of affirmative action on employee bulletin boards. [Specify.]
Offer access to those portions of the affirmative action program that will enable employees to avail themselves of its benefits.
The Company [has developed and] will develop the same internal procedures to insure that the Company's obligation to provide equal employment opportunity without regard to religion or national origin is being fully implemented as it [has developed and] will develop to insure the implementation of its overall affirmative action policy. These procedures include the appointment of a Coordinator with full responsibility for the implementation of all affirmative action programs, and a review of potential problem areas with respect to religion and national origin.
The Company [has discussed and will discuss its commitment to provide equal opportunity for all persons without regard to religion or national origin at the special meetings for employees that the Company [has scheduled and] will schedule at least once a year to discuss its overall affirmative action program and related policies and to explain individual responsibilities.
The Company [has enlisted and] will enlist the assistance and support of all recruitment sources, including employment agencies, college placement directors, and business associates, for the Company's commitment to provide equal employment opportunity without regard to religion or national origin at the same time as it informs these recruitment sources of the Company's overall equal employment opportunity policy and its affirmative action program and of its desire that recruitment sources recruit and refer minorities and women for all positions.
In doing its work force analysis, the Company [has reviewed and] will review its employment records to determine the availability of promotable and transferable members of various religious and ethnic groups. [This item and those following should not be included unless a real problem is perceived.]
The Company [has established and] will establish meaningful contacts with religious and ethnic organizations and leaders for such purposes as advice, education, technical assistance, and referral of potential employees. The organizations include: [List.]
The Company [has engaged and] will engage in significant recruitment activities at educational institutions with substantial enrollments of students from various religious and ethnic groups. [List.]
The Company [has used and] will use religious and ethnic media for institutional and employment advertising. [List.]
The Company [has accommodated and] will accommodate to the religious observances and practices of an employee or prospective employee unless it cannot do so reasonably without undue hardship on the conduct of the Company's business.
As part of its obligation, the Company [made and] will make, at a minimum, reasonable accommodations to the religious observances and practices of an employee or prospective employee who regularly observes Friday evening and Saturday, or some other day of the week, as his or her Sabbath, or who observes certain religious holidays during the year and is conscientiously opposed to performing work or engaging in similar activities on those days, when accommodation can be made without undue hardship on the conduct of the Company's business. In determining whether a particular religious observance or practice can be respected without undue hardship on the conduct of the Company's business, the Company [has considered and] will consider business necessity, financial cost and expenses, and resulting personnel problems.
CAUTION
If your program is audited, expect the Equal Opportunity Specialist to seek changes, large or small. The Department of Labor has published its "Compliance Manual," which is available from the Government Printing Office in Washington. It is an invaluable aid.
This form has not been verified for compliance with the law of any particular state. Pickup and use of this form from the Nicolai Law Group, P.C.. web site does not make you a client of Nicolai Law Group, P.C. Nicolai Law Group does not promise or represent to you that this form will be legal or binding or make the agreement you expect or desire. This form is for illustrative purposes only.