REV:03/01/01
SCOPE:
Trinity Forge, Inc. is an affirmative action employer.
This procedure is the forum for providing the official
statement of the Company's equal employment
opportunity policy as well as its affirmative action
plan.
I. STATEMENT OF
POLICY ON EQUAL EMPLOYMENT OPPORTUNITY
The Trinity Forge policy of Equal Employment Opportunity
is to recruit, hire, promote, reassign, compensate and
train for all job classifications without regard to race,
color, religion, sex, age, national origin, disability,
or veteran status.
All employment decisions and personnel actions shall be
administered in accordance with the principle of equal
employment opportunity.
This statement shall be posted at all facilities and
headquarters locations so that employees may have
knowledge of the commitment of management to equal
employment opportunity.
To implement this policy, the Human Resource Manager has
equal employment opportunity responsibilities.
II. IDENTIFICATION OF ORGANIZATIONAL UNITS
Trinity Forge operates a forging and machine shop in
Mansfield, Texas. As of July 1, 1993, only one employee
did not work directly in Mansfield, a Regional Sales
Manager working out of his home. For purposes of this
policy, the company is one unit.
III. REAFFIRMATION OF POLICY
The purpose of this statement is to reaffirm that it has
been and will continue to be the policy of Trinity Forge
to be an equal opportunity employer.
The Basic Equal Employment Opportunity (EEO) Policy
1. The Equal Employment Opportunity policy is to recruit,
to hire, to promote, to train, to compensate and to
reassign for all job classifications without regard to
race, color, religion, sex, age, national origin,
disability, or veteran status.
2. All applicants for employment will be considered
without regard to race, color, religion, sex, age or
national origin, disability, or veteran status.
3. There will be no discrimination with regard to race,
color, religion, sex, age, national origin, disability,
or veteran status in employment matters relative to all
employees of Trinity Forge. Such matters include (but are
not limited to) facilities, promotions, demotions,
transfers, layoffs, terminations, or other terms and
conditions of employment.
4. Every employee of Trinity Forge shall adhere to this
policy.
5. Employment practices of Trinity Forge will conform to
the requirements of all applicable laws and regulations
nondiscrimination in employment.
6. This Affirmative Action Plan has been adopted to
ensure that EEO policy of Trinity Forge, as well as its
legal obligations, are translated into positive efforts
which will improve employment opportunities for employees
and applicants without regard to race, color, religion,
sex, age, national origin, disability or veteran
status.
Compliance with Sex Discrimination Guidelines
1. Trinity Forge actively recruits both men and women for
all jobs. Referral sources are informed that Trinity
Forge has no specific sex preference and seeks only
qualified applicants without regard to race, color,
religion, sex, age or national origin.
2. Advertisements, when placed, are put in a general
category or, when not available, the same advertisement
is placed in both the male and female columns with no sex
preference indicated. All advertisements are followed by
"An Equal Opportunity Employer."
Policies and practices
1. All written personnel policies clearly stipulate that
all policies and practices apply to every employee on an
equal basis regardless of the sex of the employee.
2. All employees have an equal opportunity for any job
for which they are qualified. Sex is not considered a
bona fide occupational qualification for any job within
Trinity Forge.
3. No distinction based upon sex is made in regard to
employment opportunities, wages, benefits, hours or other
conditions of employment.
4. There is no distinction between the employment
treatment of males and females on the basis of marital
status.
5. Employment decisions are not affected by an
applicant's family status.
6. Trinity Forge provides appropriate and equal physical
facilities to both female and male employees.
7. No distinction is made between males and females with
regard to retirement.
Discriminatory Wages
1. Wage schedules and rates are not related to the sex of
any employee.
2. Persons of any one sex are not restricted to any
certain job classifications. Jobs in all classifications
are open to all qualified employees regardless of
sex.
Pregnancy and Medical Conditions
1. Women are not penalized in their employment because of
time spent away on account of childbearing or related
medical conditions. Our leave policy includes provisions
for leave due to disability for a pregnancy related
condition.
2. Disabilities caused or contributed to by pregnancy,
childbearing or related medical conditions are treated
the same as disabilities caused or contributed to by
other medical conditions.
3. Trinity Forge does not tolerate sexual harassment of
any kind in its workplace.
4. Compliance with Guidelines on Discrimination Because
of Religion or National Origin
Equal Employment Policy -- Trinity Forge does the
following to ensure that all applicants and employees are
not discriminated against because of religion or national
origin:
a. Trinity Forge reviews employment practices to ensure
that members of various religious and/or ethnic groups
are given equal job opportunities.
b. To ensure nondiscrimination based on religion or
national origin, Trinity Forge is involved in the
following outreach and recruitment activities:
(1) Trinity Forge communicates its obligations to provide
equal employment opportunity without regard to religion
or national origin to all employees, including managers
and supervisors.
(2) Internal procedures exist at each level to implement
equal employment opportunity without regard to religion
or national origin.
(3) Trinity Forge informs all employees of its commitment
to equal employment opportunity without regard to
religion or national origin.
(4) Recruitment sources provide equal employment
opportunity without regard to religion or national
origin.
Accommodations to Religious Observance and Practice --
Trinity Forge accommodates the religious observance and
practices of employees or prospective employees except
where such accommodation causes undue hardship in the
conduct of Trinity Forge business. The extent of Trinity
Forge obligation is determined by considering business
necessity and expense.
Nondiscrimination -- In implementing its EEO policy
regarding nondiscrimination because of religion or
national origin, Trinity Forge does not discriminate
against any qualified employee or applicant for
employment because of race, color, religion, sex, age or
national origin.
Compliance with Guidelines on Discrimination Because
of Handicap
1. Equal Employment Policy -- Trinity Forge does the
following to ensure that all applicants and employees are
not discriminated against because of handicap:
a. All employment practices and procedures are thoroughly
and systematically reviewed to ensure that they do not
contain any inhibitors to the recruitment, hire or
advancement of handicapped persons. Applications of both
applicants and employees who are handicapped persons are
reviewed to identify their qualifications and to ensure
that they are given full consideration for job vacancies
and training opportunities.
b. Each organizational unit reviews annually the physical
and mental job qualification requirements to ensure that,
to the extent qualification requirements tend to screen
out qualified individuals with handicaps, they are
job-related and are consistent with business necessity
and the safe performance of the job. Trinity Forge
accepts the burden to demonstrate that it has complied
with the requirements of this paragraph. Trinity Forge
recognizes that this section does not prohibit conducting
a comprehensive medical examination prior to employment
provided the results of such an examination shall be
based only in accordance with the requirement of this
section. Information obtained in response to such
inquiries shall be kept confidential.
c. Definition of handicap -- The Commission on Human
Rights Act states that a handicapped person means a
person who has a disability or mental or physical
handicap, including mental retardation, hardness of
hearing, deafness, speech impairment, visual handicap,
being crippled, or any other health impairment that
requires special ambulatory devices or services. The
term, as it relates to employment, does not include any
individual who is an alcoholic or drug abuser, or whose
use of alcohol or drugs prevents such individual from
effectively performing the duties of the job in question,
or whose employment, by that reason of such alcohol or
drug abuse, would constitute a threat to property, the
safety of others, or the job performance of other
employees. Disabilities specifically exempted by the
Americans with Disabilities Act are not a
"handicap" under this definition.
2. Practices
a. All personnel procedures are reviewed to ensure that
they do not discriminate on the basis of handicap in
salary, benefits, training, and promotion; and that
personnel practices and procedures are designed to
provide for affirmative action and proper consideration
of a worker's qualifications. The mental and physical
requirements of a position are reviewed by management
annually to ensure that they are not discriminatory
toward a qualified individual with a handicap who is
capable of performing the job without undue hardship to
Trinity Forge.
b. As part of Trinity Forge affirmative action effort,
facilities are inspected to ensure that, where practical,
architectural barriers have been removed for individuals
with handicaps.
c. Part of Trinity Forge affirmative action effort for
employees with handicaps includes reasonable
accommodations to the needs of individuals with handicaps
to allow them to perform jobs they are qualified for
without undue hardship to Trinity Forge.
d. If it appears an individual is qualified for a job,
but will not be able to perform the job due to a handicap
and no reasonable accommodation is made, the Personnel
Manager should be asked to review the job to determine
whether reasonable accommodation is possible.
e. Compensation to employees with handicaps is not
reduced due to the receipt of other compensation benefits
from other sources.
F. Compliance with Guidelines on Discrimination Because
of Veteran Status
1. Equal Employment Policy -- Trinity Forge does the
following to ensure that all employees and applicants are
not discriminated against because of their being a
disabled veteran or a veteran of the Vietnam era:
a. All personnel practices are thoroughly and
systematically reviewed to ensure careful consideration
of job qualifications of known disabled veteran
applicants for job vacancies filled either by hiring or
promotion, and for all training opportunities offered or
available. Only that portion of an individual's
military record, including discharge papers, relevant to
the specific job qualifications for which the veteran may
be considered.
b. Each organization unit shall take affirmative action
steps to treat qualified disabled veterans or veterans of
the Vietnam era without discrimination in all employment
practices. In offering employment or promotions to
disabled veterans and veterans of the Vietnam era,
Trinity Forge does not reduce the amount of compensation
offered because of any disability income, pension or
other benefit the applicant or employee received from
another source.
c. Definition of affected groups:
(1) Disabled Veteran -- a person entitled to disability
compensation for a disability rated at 30% or more or a
person whose discharge or release from active duty was
for a disability aggravated or incurred in the line of
duty.
(2) Qualified Disabled Veteran -- a disabled veteran as
defined above who is capable of performing a particular
job with reasonable accommodation to his/her
disability.
(3) Veteran of the Vietnam Era -- a person who served on
active duty for a period of more than 180 days, any part
of which occurred between August 5, 1964 and May 7, 1975
and was discharged or released there from with other than
a dishonorable discharge, or who was discharged or
released from active duty for a service-connected
disability if any part of such active duty occurred
between the aforementioned dates. Veterans of the Vietnam
era discharged or released prior to 1991 with anything
but a dishonorable discharge will be covered under the
Act.
2. Practices -- all personnel procedures are evaluated to
ensure freedom from stereotyping disabled veterans and
veterans of the Vietnam era in a manner which limits
their access to all jobs for which they are
qualified.
IV. DISSEMINATION OF POLICY
A. External Dissemination: the policy of Trinity Forge on
Equal Employment Opportunity has been and will continue
to be communicated to outside sources through the
following methods:
1. Trinity Forge utilizes a number of sources for
recruiting. The recruitment sources have been advised of
its policy of Equal Employment Opportunity. All
employment advertising contains its Equal Employment
Opportunity statement. Contacts with these recruiting
sources stipulate that each organizational unit is
interested in the sources active recruitment and referral
of minorities, females, handicapped individuals, and
disabled and Vietnam era veterans for the available
position. The recruitment sources are: Texas Employment
Commission, private employment agencies, newspaper
advertisements, local mailers and employee referrals.
2. The Equal Opportunity clause may be incorporated into
appropriate invoices, purchase orders, leases, contracts,
and other documents to which Trinity Forge is a
party.
3. Minority and non-minority men and women are shown when
employees are pictured in recruiting brochures.
4. Written notification of Trinity Forge EEO policy is
sent to all significant subcontractors, vendors and
suppliers, requesting appropriate action on their
part.
B. Internal Dissemination: Trinity Forge will continue to
disseminate its Equal Employment Opportunity Policy
internally by the following:
1. The policy is posted on Trinity Forge bulletin boards
throughout the facilities.
2. Current EEO posters are posted prominently.
3. The Affirmative Action Plan is available for review by
all employees through the Trinity Operating Procedures
(TOPs) manual.
4. All employees engaged in recruitment, employment,
training, and similar activities have received thorough
instructions as to their responsibilities with regard to
implementation of this policy and program.
5. The Trinity Forge Equal Employment Opportunity Policy
and Affirmative Action Plan are addressed through
discussions and e-mails with supervisors in an effort to
assist supervisors in their relations with minority group
employees.
6. In 1994 and thereafter, the company will continue to
communicate its Equal Employment Opportunity Policy and
Affirmative Action Plan to all employees through Trinity
Forge publications (should there be any), bulletin board
notices, supervisor contacts, and in employee
meetings.
V. RESPONSIBILITY FOR IMPLEMENTATION
A. President -- as a Board-appointed executive official
of Trinity Forge, has the overall responsibility for the
effective development and implementation of the Equal
Employment Opportunity policy. The President has the full
support of the Board of Directors, the CEO and the staff.
The responsibilities include:
1. Assistance in the identification of problem areas and
establishment of goals and objectives for Trinity
Forge.
2. Periodic review of training programs, hiring, career
and promotion patterns to remove impediments to the
attainment of career goals and objectives.
3. Discussions with managers and supervisors to be
certain that Trinity Forge, Inc. policies are being
followed.
4. Periodic review to ensure that each facility is in
compliance in areas such as:
a. Required posters are properly displayed.
b. All facilities provided for employees are desegregated
by policy and use. Comparable facilities will be provided
for both sexes.
c. All affected employees are afforded a full opportunity
and are encouraged to participate in all Trinity Forge
sponsored educational, training, recreational and social
activities.
d. Reasonable accommodation is made for any employee with
a disability.
B. Human Resource Manager -- has the day-to-day
responsibilities for the implementation of the policy,
accountable to the President. As the manager with equal
employment responsibilities, the Personnel Manager has
the full support of the Board of Directors, the CEO, the
President and the staff. The responsibilities
include:
1. Developing policy statements, Affirmative Action
Programs and internal and external communication
techniques.
2. Assisting in the identification of problem areas.
3. Assisting supervisors in arriving at solutions to
problems.
4. Designing and implementing reporting systems that
will:
a. Measure the effectiveness of the programs.
b. Indicate the need for remedial action.
c. Determine the degree to which goals and objectives
have been attained.
---- Part of the audit and reporting system includes:
a. Maintaining active personnel files and job applicant
registers.
b. Maintaining lists of employees by area and
classification.
c. Reporting job openings to the state employment
agency.
5. Serving as liaison between organizational unit and
enforcement agencies.
6. Serving as liaison between each organizational unit
and minority organizations, women's organizations and
community action groups concerned with employment
opportunities of affected groups.
7. Keeping management informed of the latest developments
in the entire equal employment opportunity area.
C. Managers and Supervisors -- held responsible for
initiating, administering and controlling activities
within their respective areas of responsibility in order
to ensure full implementation of the policy. The
responsibilities include:
1. Understand that their work performance is being
evaluated on the basis of their equal employment
opportunity efforts and results as well as other
criteria;
2. Take action to prevent harassment of employees placed
through affirmative action efforts.
VI. RECRUITING
A. Normal Recruiting -- recruiting through normal
channels will continue.
B. Employment Agency Contact -- the entities mentioned in
Section IV.A will continue to be contacted in an effort
to recruit job applicants from groups affected by this
program. The Personnel Manager, through personal contact,
will ensure that the Trinity Forge particular recruiting
goals and problems are understood by the agency
personnel. These entities will continue to be notified of
openings.
VII. INTERNAL AUDITING AND REPORTING SYSTEM
The Personnel Manager is responsible for the
establishment and implementation of the auditing and
reporting system. He/she reviews this system on an annual
basis. The reporting and auditing system includes:
A. Maintaining accurate and up-to-date records on all
applicants, hires, promotions, transfers, and
terminations by race, sex, handicap and veteran
status.
B. Reviewing all promotions, transfers and terminations
to be certain all employees are treated on a fair and
equitable basis.
C. Reviewing all section, promotional and training
procedures to be certain that they are
nondiscriminatory.
D. Performing a utilization analysis and, with top
management, updating the Affirmative Action Program.
E. Informing top management of the effectiveness of the
policy and making recommendations for improvement, if
necessary.
VIII. EMPLOYEE ENTRY AND MOVEMENT PROCESS
A. Employment
1. Recruitment
a. Recruitment for hourly and salaried positions is a
function of the Human Resource Manager. Referrals are
made by employees, other individuals, schools and the
state employment service.
b. The entities listed in Section IV.A have been
contacted concerning openings and will continue to be
contacted. Letters concerning vacancies will specifically
state that qualified applicants of all races, colors,
religion, sexes, national origins, religions, handicap or
veteran status shall be sent for interviews, if any; and
that Trinity Forge is interested in referrals of female,
minority, veteran and handicapped applicants.
2. Personnel Interviewing and Processing
a. When openings exist or are anticipated, applicants are
referred to the personnel office. No preference is given
in interviewing order because of race, color, religion,
national origin, sex, disability or veteran status. The
applicant may or may not be referred to the appropriate
department head for an interview.
b. Application forms do not include questions designed to
discover race, religion, sex, national origin or age.
Questions concerning handicap shall only be asked for the
purpose of determining necessary accommodation to any
handicap, and questions concerning veteran status are
only for the purpose of affirmative consideration.
c. All applications for employment are retained for a
period of one year.
B. Promotion -- employees are considered for promotions
without discrimination based on race, color, religion,
sex, age, national origin, disability or veteran status.
Where there are lines of progression, there are no
separate female or minority lines, and no discriminatory
impediments to the movement into, out of, or within
progression lines.
C. Salary and Wage Plans -- classification and
compensation of affected employees follow the same plan
and program as that of other employees performing like
work, without distinction of any kind.
D. Training-- Regular training programs have been
established in such areas as shop production. These and
other special programs include on-the-job training and
are made available to each employee regardless of race,
color, religion, age, sex, national origin, veteran
status or disability.
IX. COMPLAINTS OF DISCRIMINATION
Trinity Forge encourages employees to notify their
supervisor or any other supervisor or manager if they
feel the Affirmative Action Plan is failing to meet plan
objectives. For cases where an employee or applicant
feels he or she has been improperly discriminated against
or has been sexually harassed, the following procedure
has been developed to encourage resolution of
complaints:
A. The employee or applicant is to notify any instance of
discrimination to his/her supervisor or any other manager
with whom he/she feels comfortable confiding.
B The supervisor/manager to whom the employee/applicant
reports will get as many details as possible regarding
the alleged discrimination and report to the Personnel
Manager.
C The Human Resource Manager will obtain from the
complainant: name, address, telephone number, a
description of the act (s) alleged to be discriminatory a
brief statement describing the complainant's handicap
(and job skills or training, if any) and identification
of the specific action and the individuals involved in
the alleged violation. The Personnel Manager is
responsible for gathering further information as
necessary and for coordinating with the President or CEO
to assure proper resolution and to provide personal
assistance to the employee, if needed.
D. Appropriate action to resolve the complaint will be
taken in a timely manner.
E. No adverse employment action will be taken against
employees for utilizing the complaint procedures or
participating in an investigation.
F. The employee's complaint as well as the
investigation will be kept confidential to the extent
possible.
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