EQUAL EMPLOYMENT OPPORTUNITY POLICY & PROCEDURES

POLICY:

It is the policy of the Company to afford non-discriminatory and equal employment opportunity to qualified individuals regardless of their race, color, sexual orientation, religion, ancestry, sex, national origin, age, physical or mental disability, marital or veteran status, and to conform with the content and spirit of applicable equal opportunity and affirmative action laws and regulations in accordance with Title VII of the Civil Rights Act of 1964.

PROCEDURES:

In keeping with the intent of this policy, the Company will adhere strictly to the following Human Resources practices:

1. Recruitment, hiring, and promotion of employees in all job classifications will be conducted without regard to race, color, sexual orientation, religion, ancestry, sex, national origin, age, physical or mental disability, marital or veteran status, except where a bona fide occupational qualification exists.

2. Employment and promotional decisions will be made in such a manner as to further the principle of equal employment opportunity based upon objective and related selection criteria.

3. Personnel actions in the areas of compensation, benefits, transfers, training and development, educational assistance, and social and recreational programs will be administered- without regard to race, color, sexual orientation, religion, ancestry, sex, national origin, age, physical or mental disability, marital or veteran status, except where a bona fide occupational qualification exists.

4. All forms of discrimination with regard to employees or applicants for employment, including any form of racial slurs, religious intimidation, epithets, sexual advances, or harassment, are prohibited. Any charges of discrimination will be investigated and, if warranted, appropriate disciplinary action taken against an individual, up to and including termination of employment with the Company.

5. Overall responsibility for the development and execution of the affirmative action program and equal opportunity compliance is the responsibility of Company management; however, the day-to-day administration of the program is the responsibility of the Human Resources Department.

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