January 1, 2016
EQUAL EMPLOYMENT OPPORTUNITY POLICY STATEMENT
EFCO Corporation is an equal opportunity employer. It is the policy of EFCO to prohibit discrimination of any type and to afford equal employment opportunities to employees and applicants, without regard to race, color, religion, sex, national origin, age, disability, or veteran status. EFCO will conform to the spirit as well as the letter of all applicable laws and regulations. EFCO will take action to employ, advance in employment and treat qualified Vietnam era veterans and disabled veterans without discrimination in all employment practices.
II. SCOPE OF POLICY
The policy of equal employment opportunity and anti-discrimination applies to all aspects of the relationship between EFCO and its employees, including but not limited to:
• Working conditions
• Wages and salary administration
• Employee benefits and application of policies
The policies and principles of equal employment opportunity also apply to the selection and treatment of independent contractors, personnel working on our premises who are employed by temporary agencies and any other persons or firms doing business for or with EFCO.
III. DISSEMINATION AND IMPLEMENTATION OF POLICY
The officers of EFCO will be responsible for the dissemination of this policy. Directors, managers and supervisors are responsible for implementing equal employment practices within each department. The Human Resources Department is responsible for EFCO’s overall compliance, and shall maintain personnel records in compliance with applicable laws and regulations.
Company practices that support this policy include the following:
• EFCO displays posters regarding equal employment opportunity in areas highly visible to employees.
• All advertising for job applicants includes the statement “An Equal Opportunity Employer.”
• EFCO will post all required job openings with the appropriate state agency.
• EFCO forbids retaliation against any individual who files a charge of discrimination, reports harassment, or who assists, testifies or participates in an equal employment proceeding.
• Employees are required to report to a member of management, Human Resources representative or the General Counsel any apparent discrimination or harassment. The report should be made within forty-eight hours of the incident.
• The Human Resources representative should promptly notify the VP of Human Resources of all incidents or reports of discrimination or harassment.
Harassment is a form if discrimination and violates this policy. Prohibited sexual harassment is defined as unwelcome sexual advances, request for sexual favors, and other verbal or physical conduct of a sexual nature when:
• Submission to such conduct is made either explicitly or implicitly as a term or condition of an individual’s employment.
• Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individuals.
• Such conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.
VI. REMEDY FOR VIOLATION OF POLICYViolations of this policy, regardless of whether or not an actual law has been violated, will not be tolerated. EFCO will investigate every issue that is brought to its attention in this area and will take appropriate disciplinary action, up to and including termination of employment.