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
1. 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.
2. 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.
3. 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.
E. 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.
