AFFIRMATIVE ACTION PLAN FOR INDIVIDUALS WITH DISABILITIES

I.               REASONABLE ACCOMMODATION

The Company endeavors to reasonably accommodate qualified disabled applicants and employees so that they can perform the essential functions of jobs at the Company.  

II.             REVIEW OF JOB QUALIFICATIONS

The Company reviews its job qualifications as positions become available.

III.            STATEMENT OF POLICY

                 A.        Policy

It is the policy of the Company to take affirmative action to ensure equal employment opportunity for disabled persons.  This policy covers all aspects of employment including, but not limited to, hiring, assign­ment, promotion, demotion, transfer, termina­tion, wage and benefit administration, and selection for training.  

In order to implement this policy, the Company will make good faith efforts to accommodate the physical and mental limitations of quali­fied disabled employees or applicants unless such an accommodation would impose undue hardship on the Company's busi­ness, require substantial financial cost and ex­pense, or place in jeopar­dy the safety of the disabled individuals, his or her co-work­ers, the Company's security, customers of this Company or the general public. 

B.             Limitations

Individuals who meet the following criteria will be considered for employment or promo­tion, if otherwise qualified:

1.         The employee or applicant is qualified to perform the essential functions of the job or could be qualified to perform the essential functions if the Company made a reasonable accommodation.

2.         The employee or applicant can perform the essential functions of the job without unreason­able risks to the safety of the individual, his or her co-workers, the Company's security or the general public.

                 C.        Interpretation

Each disabled employee or applicant will be evaluated on an individual basis with respect to his or her ability to perform a particular job.  Disabilities which interfere with the performance of a specific job shall not disqualify a person from employment in another job if the criteria for that job are satisfied.

IV.            DEFINITION OF DISABLED PERSON

Federal regulations define a "disabled individual" as any person who:

A.        has a physical or mental impairment which substan­tially limits one or more of such person's major life activities; or

B.         has a record of such impairment; or

                 C.        is regarded as having such impairment.

V.             AFFIRMATIVE ACTION MEASURES

The Company will consider the following affirmative action measures:

A.        Posting, in appropriate places, informational posters or notices required by federal and state laws and regula­tions pertaining to the employment of disabled persons.  

B.         Documenting accommodations made to assist disabled applicants or employees.  Such records will be supplied to and maintained by the EEO Coordinator.  Department Managers and supervi­sors will assist the EEO Coordinator in the documentation of accommodation efforts.  

C.        Placing special emphasis, insofar as it is economically feasible and practical, upon the removal of architectural barriers to the disabled when designing new construction or remodeling old facilities.  

D.        Taking affirmative action to employ and advance in employment qualified disabled individuals at all levels of employment, including the executive level.  Such action will apply to all employment prac­tices including, but not limited to, the following:  hiring; upgrading; demotion or transfer; recruitment or recruitment advertis­ing; layoff; termination; rates of pay or other forms of compensation; and, selection for training, including apprenticeship.  

1.         Proper Consideration of Qualifications

To the extent possible, the Company will review its personnel proce­dures to determine whether such procedures assure care­ful, thorough and systematic consid­eration of the job qualifications of known disabled applicants and employees for vacancies filled either by hiring or promotion, and for all training opportunities offered or available.  To the extent that it is necessary to modify personnel proce­dures, the Company will develop new procedures for this purpose and will incor­porate them in our affir­mative action program.  These procedures will be designed to facilitate review by the EEO Coordi­nator and/or representa­tives of federal or state compliance agencies.  

                             2.         Physical and Mental Qualifications.

(a)        The Company regularly, and at least annually, will review all physi­cal or mental job qualification requirements to insure that, to the extent qualification requirements tend to screen out qualified disabled individuals, they are job­-related, and consistent with business necessity, and/or re­quired for the safe performance of the subject job.  See Section II, above.

(b)        Whenever the Company utilizes physical or mental job qualification requirements in the selection of applicants or employees for employ­ment or any change in employment status, such as promotion, demotion or training, to the extent that qualification requirements tend to screen out qualified disabled individuals, the requirements should be related to the specific job or jobs for which the individual is being considered, consistent with business necessity and necessary for the safe performance of the job.  

(c)        Whenever an applicant or employee provides information about a physical or mental impairment that substantially limits a major life activity or such information is revealed through a post-offer medical examination, such information shall be kept confidential, except that:  

(i)         Supervisors and managers may be informed regarding restrictions on the work or duties of disabled individuals and appropriate accommodations;

(ii)        First aid and safety personnel may be informed, when and to the extent appro­priate, of conditions that might require emergency treatment; and,

(iii)       Government officials investi­gating compliance with the Vocational Re­habili­tation Act shall be informed as appropriate.

(iv)       Such a medical examination shall consider only job related character­istics in a fair and consistent manner.

3.         Accommodations to Physical and Mental Limita­tions of Employees.

The Company will endeavor to reasonably accommodate the physical or mental impairment that substantially limit major life activities for employees and applicants, unless such an accommodation would impose an undue hardship on the conduct of the Company's business.  In determining the extent of our ability to reasonably offer an accommodation, the following factors, among others, will be considered:  (1) business necessity; (2) financial cost; and, (3) resulting benefit to the Company and the disabled individual.  See Section I, above.  

4.         Compensation.  

In offering employment or promotions to disabled individuals, the Company will not reduce the amount of compensation offered because of an individual's receipt of disability income, pension or any other benefit from another source.  

5.         Outreach, Positive Recruitment and External and Internal Dissemination of Policy.

We will review our employment practices to deter­mine whether personnel programs provide the re­quired affirmative action for employment and advancement of quali­fied disabled individuals.  

Based upon the findings of such reviews, we will, as is appropriate, undertake outreach and positive recruitment activities, such as those listed below.  It is not contem­plated that we will necessarily undertake all of the listed activities or that our activities will be limited to those listed.  The scope of our efforts clearly will depend upon the relevant circum­stances, including our size, re­sources and the extent to which existing employ­ment prac­tices are adequate.  Thus, we will consider the following:

(a)        Sending written notification of the Company's EEO/AA policy commitments to vocational rehabilitation agencies for the disabled.

(b)        Developing internal communica­tion proce­dures to disseminate our obligation to engage in affirmative action efforts to employ qualified disabled individuals, to foster understanding, acceptance and support among our executives, management staff, supervisors and all other employees and encouraging such persons to take the necessary action to aid in meeting this obligation.

(c)        Developing reasonable internal proce­dures to ensure that our obligation to engage in affirmative action to employ and promote quali­fied disabled individuals is fully implemented.

(d)        Informing employ­ees and prospective employees periodically about our commitment to engage in affirmative action to increase employment opportunities for qualified disabled individuals.

(e)        Enlisting the assis­tance and support of recruitment sources of or for disabled individuals to assist us in our efforts to provide meaning­ful employment opportunities to qualified disabled individuals.

(f)         Reviewing employment records to determine the availability of promotable and transfer­able quali­fied disabled individuals pres­ently employed, and to determine whether their present and poten­tial skills are being uti­lized or devel­oped.

(g)        Including disabled employ­ees when employees are pictured in consumer, promo­tional or help-wanted advertising.

(h)        Sending written notification of this policy to all subcontractors, vendors and suppliers. 

(i)         Taking positive steps to attract qualified disabled persons not currently in the workforce who have requi­site skills and can be recruited through affir­mative action measures.

6.         Internal Dissemination of Policy

Our outreach program will receive strong support from supervisory and management personnel.  To assure employee cooperation and participation in our efforts, we will adopt, implement and dissemi­nate this policy internally, by considering use of the follow­ing procedures, as deemed appropriate:

(a)        Including it in our policy manual;

(b)        Publicizing it in the Company's annual report and other reports;

(c)        Conducting special meetings with executive, management and supervi­sory personnel to explain the intent of the policy and individu­al respon­sibility for effective implementa­tion, clarifying the Company's Policy;

(d)        Scheduling special meetings with all employees to discuss the Policy and explain individual employee responsibility.

(e)        Discussing the Policy thoroughly in both employee orientation and management train­ing programs;

(f)         Including articles on accomplishments of disabled workers in the Company's publications;

(g)        Posting the Policy on the Company's bulletin boards, including a state­ment that em­ployees and applicants are protected from coercion, intimi­dation, interference or discrimina­tion for filing a complaint or assisting in any investigation of dis­crimination against any disabled person; and,

(h)        Including disabled employees when employees are featured in employee handbooks or similar publications for employees. 

7.         Responsibility for Implementation.

Our EEO Coordinator will imple­ment this affirmative action pro­gram, and will consider:

(a)        Developing policy statements, affirma­tive action programs, and internal and external communica­tion procedures.  The procedures may include regular discussions with managers, supervisors and employees to ensure that this policy is followed.  In addition, managers and supervisors may be advised that:

(i)         As a general management objective, their work performance is being evaluated on the basis of their affirmative action efforts and re­sults, as well as other criteria.

(ii)        The Company is obligated to prevent harassment of employees placed through affirmative action efforts.

(b)        Identifying problem areas through discussions with management and known disabled employees, assist in the implementation of our affirmative action programs, and develop solutions to problems.

(c)        Designing and implementing audit and reporting systems that will:

(i)         Measure effectiveness of our programs;

(ii)        Indicate the need for remedial action;

(iii)       Determine the degree to which our objec­tives have   been attained;

(iv)       Determine whether known disabled employees have had the opportunity to participate in educational, training, recrea­tional and social activities provided by the Company; 

(v)        Ensure that the Company is in compliance with applicable state law and all im­plementing regula­tions.

(d)        Serving as liaison between the Company and federal and state compli­ance agencies.

(e)        Serving as liaison between the Company and organizations of and for disabled persons, and arrange for the active in­volvement by Company representatives in the community service programs of local organi­zations of and for the disabled.

(f)         Keeping management informed of the latest devel­opments in the entire affirmative action area.

(g)        Arranging for career counseling for known disabled employees.

E.         Development and Execution of Affirmative Action Programs.

The Company will consider the development and execution of the following programs:

1.         Making job qualification requirements avail­able to all members of manage­ment involved in the recruitment, screen­ing, selection, and promotion process.

2.         Evaluating the total selection process including training and promotion to ensure freedom from the stereotyping of disabled persons in a manner which limits their access to jobs for which they are qualified.

3.         Selecting and training all personnel involved in recruit­ment, screen­ing, selection, promotion, disciplinary, and related processes to ensure that the commit­ments in this Affirmative Action Plan are implemented.

4.         Holding formal briefing sessions with repre­sentatives from recruiting sources, during which the Company may provide, inter alia, explana­tions of current and anticipated future job openings, position descriptions, worker speci­fications, explanations of the selection process and recruit­ing literature. Making arrangements for referral of applicants, follow-up with sources and feed-back about the disposi­tion of referred applicants.

5.         Including quali­fied disabled persons on the personnel relations staff.

6.         Having employees with disabilities available for participation in career days, youth motivation programs, and related activities in their communities.

7.         Incorporating special recruiting efforts at schools or other insti­tutions to reach disabled students.

8.         Participating in work study programs with rehabilitation facilities and schools which specialize in training or educating disabled individuals.

9.         Using available resources to continue or establish on the job training programs.

*                     *                    *                    *

Although the Company does not use sheltered workshops, it realizes that contracts with sheltered workshops do not constitute affirmative action in lieu of employment and advancement of qualified disabled individuals in the contractor's own workforce.  Contracts with sheltered workshops may be included within our affirmative action program, if the sheltered workshop trains employees for the Company and the Company is obligated to hire trainees at full compensation when such trainees become qualified as a "qualified disabled individual" as defined in 41 CFR §60-741.2.

F.         The EEO Coordinator will post the following notice to disabled individ­uals:

Invitation To Disabled Individuals To Self Identify 

The Company is committed to taking affir­mative action to employ and advance in employ­ment qualified disabled individuals.  If you have a physical or mental impairment that substantially limits a major life activity, and would like to be con­sidered under our affirmative action program, please tell us.  You may inform us of your desire to benefit under the program after a job offer has been made and/or at any time thereafter.  Submission of this information is voluntary and refusal to provide it will not affect the Company's decision whether to offer you employment or subject you to discharge or disci­plinary treat­ment.  Informa­tion obtained will be kept confi­dential, except that (1) supervisors and mana­gers may be in­formed regarding restric­tions on the work or duties of disabled individuals and necessary accommodations; (ii) first-aid and safety personnel will be informed, to the extent appropri­ate, of conditions that might require emergency treatment; and (iii) representatives of federal and state agencies may review such records, as required.

If you are disabled, we would like to include you under our Affirmative Action Plan.  It would assist us if you tell us about (1) any special methods, skills and procedures which qualify you for jobs that you might not other­wise be able to perform because of your disability, so that you will be considered for any position of that kind, and (2) the accommoda­tions which we could make which would enable you to perform the essential functions of the job properly and safely, includ­ing special equip­ment, changes in the physical layout of the job, elimination of certain duties relating to the job, or other accommoda­tions.  To participate, please see Charles Small, the EEO Coordinator.

Employees may request to see copies of the affirmative action plan during regular hours from our EEO Coordinator.

G.        The Company will consider maintaining the following records con­cerning disabled employees covered by this policy:

(1)        Annotating appropriate personnel form(s) of each known disabled indi­vidual to identify each vacancy for which that disabled individual has been considered and making such records available for review by the Company's person­nel officials for use in investigations and inter­nal compliance reviews.

            (2)        Placing notations on the personnel record of each known disabled employee of each training promotion for which the disabled employee has been considered, and the result of that consideration, including the reasons for any decision.

(3)        Appending to the personnel file or application form a statement of reasons for rejection each time that a known disabled employee or applicant is rejected for employment, promotions or training. This statement will include a comparison of the qualifica­tions of the disabled applicant or employee and the person(s) selected, as well as a description of the accommo­dations considered.  This statement will be made available to the applicant or employee concerned as appropriate.

            (4)        Including with the application form or personnel record a description of any accommodation which makes it possible for a disabled individual to perform a job.