Equal Employment Opportunity, Affirmative Action and Diversity

POLICY

The Conservancy will not condone or permit discrimination, including actions that create a hostile work environment, against any employee or applicant for employment based on race, color, religion, sex, national origin, age, disability, sexual orientation, military or veteran status or other protected status.  It is the Conservancy's policy to encourage and support a work environment that respects differences and provides all employees with self respect, dignity, and fairness.

The Conservancy will actively promote diversity in its workforce. Diversity refers to human differences, including those based on culture, race, color, religion, sex, national origin, age, disability, sexual orientation, military or veteran status or other status protected by law.

The benefits the Conservancy derives from the diversity of its workforce include:

• A variety of viewpoints and perspectives in decision-making;
• Enhanced innovation and creativity;
• and A broad pool of qualified employees.

PURPOSE

To prohibit discrimination based on an individual’s protected status, to promote affirmative action, and to advance diversity in the workforce in the interests of the success of the mission.

Approved by the Board of Directors on March 15, 1996.  Revisions approved by the Board of Directors on June 11, 1999, October 4, 2002, and January 19, 2007.

REFERENCES, RESOURCES, and EXPLANATORY NOTES:

The attached Statement of Policy is part of and incorporated in this Policy.

STATEMENT OF POLICY

Equal Employment Opportunity and Affirmative Action

The Conservancy, through its responsible managers, recruits, hires, upgrades, trains, transfers, and promotes in all job titles without regard to race, color, religion, sex, national origin, age, disability, sexual orientation, military or veteran status or other status protected by law.

1. Managers ensure that all personnel actions such as compensation, benefits, layoffs, returns from layoffs, Conservancy-sponsored training, educational tuition assistance, and social and recreational programs, are administered without regard to race, color, religion, national origin, sex, age, disability, sexual orientation, military or veteran status or other status protected by law. 
2. Managers base employment decisions on the principles of equal employment opportunity and with the intent to further the Conservancy’s commitment to equal employment opportunity and affirmative action.  At no time will any covered employee, or covered applicant for employment, who exercises his/her rights pursuant to the Conservancy’s Equal Employment Opportunity and Affirmative Action Policy be subject to discipline, or have his/her opportunities for employment adversely affected in retaliation for having exercised such rights.
3.  Managers take affirmative action to ensure that qualified minority group individuals, females, disabled veterans, other protected veterans, recently separated veterans and persons with disabilities are introduced into the workforce, encouraged to aspire for promotion, and considered as promotional opportunities arise.
4. The Conservancy invites any employee or any applicant for employment in the U.S. to review the Conservancy’s written Affirmative Action Plans for Veterans and Individuals with Disabilities.  This plan is available for inspection upon request from 9:00 A.M. to 5:00 P.M. Monday through Friday at the appropriate location, as coordinated by the Worldwide Office Human Resources Function.  Any questions should be directed to a Director of the Worldwide Office Human Resources Function.
5. Applicants are encouraged to identify their race and sex if they desire to do so.  This self-identification is strictly voluntary, confidential and will not result in retaliation of any sort.  Employees are invited to self-identify as individuals with disabilities or as veterans.  This self-identification is strictly voluntary, confidential and will not result in retaliation of any sort.
6. Employees and applicants are not subjected to harassment, intimidation, threats, coercion or discrimination because they have engaged in or may engage in any of the following activities:  (1) filing a complaint of discrimination alleging violation of this policy or any federal, state, or host country anti-discrimination statute; (2) assisting or participating in an investigation, compliance review, hearing, or any other activity related to the administration of U.S. statutes, including section 503 of the Rehabilitation Act of 1973, as amended (section 503), the Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA), Title VII of the Civil Rights Act of 1964, the Americans With Disabilities Act, the Age Discrimination in Employment Act, or any other federal, state, or host country law requiring equal opportunity for disabled persons, disabled veterans, other covered veterans, and recently separated veterans; or (3) opposing any act or practice made unlawful by Section 503 or its implementing regulations in this part or VEVRAA or its implementing regulations in this part or any other federal, state, or host country law requiring equal opportunity for disabled persons, disabled veterans, other covered veterans, recently separated veterans; or (4) exercising any other right protected by Section 503 or its implementing regulations in this part or any other right protected by VEVRAA or its implementing regulations in this part.
7. The Conservancy makes reasonable accommodations to promote the employment of qualified individuals with disabilities and qualified disabled veterans, unless such accommodations would pose an undue hardship on the conduct of the Conservancy's business.

Complaint Procedure

Any employee or applicant for employment who believes that she or he has been the subject of discrimination or harassment based on race, color, religion, sex, national origin, age, disability, sexual orientation, military or veteran status or other protected status, or who believes that she or he has knowledge of such discrimination or harassment against another individual should report it immediately to his or her supervisor, any other Conservancy employee in a supervisory or managerial position, or a Human Resources Director or Manager, either in person or by telephone at 1-877-296-5108 or 1-703-841-8749. Individuals may also contact the Conservancy’s Ethics and Compliance Hotline at 1-866-213-5323. Employees may obtain information regarding international access to the hotline at the following web address: http://www.usa.att.com/traveler/.

The staff member receiving a complaint of workplace discrimination or harassment based on race, color, religion, sex, national origin, age, disability, sexual orientation, military or veteran status or other status protected by law will immediately notify a Human Resources Director or Manager and/or a Conservancy attorney, who will take appropriate steps to initiate an investigation. All investigations into charges of such discrimination or harassment will be conducted as expeditiously, discreetly, and confidentially as possible, in consultation with representatives of the Worldwide Office Human Resources Function, the Worldwide Office Legal Function, and, as appropriate, the Chief Ethics and Compliance Officer. The results of any such investigation will be communicated at least to the individual complaining of discrimination or harassment and to the alleged harasser. The Conservancy will take corrective action, if appropriate, up to and including dismissal, based on the outcome of the investigation.

No individual who initiates a complaint of discrimination or harassment in good faith or who cooperates in the investigation of such a complaint will be subjected to any form of retaliation or otherwise disadvantaged as a result. Any acts of retaliation will be treated as discrimination and will result in appropriate disciplinary action up to and including dismissal.