Element One - Demonstrated Commitment
Start with an Effective EEO Program Policy Statement(s)
· A committed agency/facility/installation head will, at the beginning of her/his tenure, and each year thereafter, issue a signed policy statement declaring the agency's position against discrimination on any protected basis.
· This policy shall be prominently posted in all personnel offices, EEO offices, and on the agency's internal website.
· This statement shall affirm the principles of equal employment opportunity and assure that EEO program requirements will be enforced by the agency head and agency management.
· Some of the principles the policy statement must assure will be upheld include, but are not limited to:
· Equal employment opportunity for all employees and applicants for employment, regardless of their race, religion, color, sex, national origin, age, or disability.
· All employees will have the freedom to compete on a fair and level playing field with equal opportunity for competition.
· Equal employment opportunity covers all personnel/employment programs, management practices and decisions including, but not limited to, recruitment/hiring, merit promotion, transfer, reassignments, training and career development, benefits, and separation.
· Workplace harassment will not be tolerated, allegations of harassment will be immediately investigated, and, where allegations are substantiated, appropriate action will be taken. (Anti-harassment policy requirements are discussed under Element Four. Agencies may choose to include all issues under one policy or issue a separate anti-harassment policy, based on their needs.)
· Reprisal against one who engaged in protected activity will not be tolerated, and the agency supports the rights of all employees to exercise their rights under the civil rights statutes.
Allocate Sufficient Resources
· An agency shall provide sufficient staffing and resources to operate the EEO program in an effective manner. For example, staff and resources should also be sufficient to enable accurate collection and analysis of data and other employment factors, including applicant information, to enable the efficient identification of barriers. This will necessarily require staff beyond the EEO office, particularly Information Management/Services.
An agency must also provide sufficient staffing, funding, and authority to eliminate identified barriers. In order to determine whether it is providing sufficient resources an agency should examine a number of factors, including:
· whether the agency employs personnel with the training and experience to conduct the analyses required by MD-715 and these instructions;
· whether the agency's EEO staff has the knowledge, skills and ability to ensure that agency EEO programs and procedures are effectively implemented;
· whether the agency has implemented adequate data collection and analysis systems that permit tracking of the information required by MD-715 and these instructions;
· whether sufficient resources have been provided to conduct effective audits of field facilities' efforts to achieve a model EEO program and eliminate discrimination under Title VII an the Rehabilitation Act;
· whether EEO training and education programs are made available to all managers and employees;
· whether a central fund or other mechanisms have been established for providing disability accommodations;
· whether there is a Disability Program Manager or other mechanisms in place to ensure coordination of disability accommodations in all major components of the agency; and
· whether there are such Special Emphasis Program Managers as may be necessary (29 C.F.R. § 1614.102(b)(4)).
Ensure All Employees are Informed
An agency must ensure that EEO program information is distributed to all employees, using all media available, including the World Wide Web or Internet.
· The agency must ensure that each employee is informed of the agency's annual EEO program policy statements, as well as the requirements and prohibitions of Title VII and the Rehabilitation Act, and the operation of the EEO complaint process and procedures.
· Federal regulation requires that EEO posters and program information be prominently posted throughout the agency's facilities, and that complainants are advised, in writing, about the complaint process (29 C.F.R. § 1614.102(b)(5), (7)).
· Distribute the agency's reasonable accommodation procedures to all managers, supervisors, and others responsible for processing requests for reasonable accommodation, and make the procedures readily available to all other employees.
· Provide training to all employees and supervisors on the operation of the EEO process, protections afforded to employees, related policy statements, and reasonable accommodation procedures.
· Demonstrate the value of EEO to the agency and employees.
· Seek input (e.g., using employee surveys and focus groups, discussions with employee advisory groups, etc.) regarding the workplace environment.