It is the policy of Blackhawk Roofing, LLC to ensure that applicants and employees are treated without regard to their race, color, religion, sex, sexual orientation, gender identity, genetic information, pregnancy status, marital status, order of protection status, national origin or ancestry, citizenship status, age, physical or mental disability unrelated to ability, military status or an unfavorable discharge from military service, or any retaliation for filing any discrimination charges.
Such action shall include employment, upgrading, demotion, or transfer; recruitment or recruitment advertising; layoff or termination; rates of pay or other forms of compensation; and selection for training, including apprenticeship, pre-apprenticeship, and on-the-job training.
EEO /Affirmative ActionPlan
Procedures to follow to assure contract compliance regarding minority employee goals and disadvantaged business enterprise goals:
· Ensure and maintain a working environment free of harassment, intimidation, and coercion at all sites and facilities where Blackhawk Roofing’s employees are assigned to work. Blackhawk Roofing will, where possible, assign two or more women to each construction project. Blackhawk Roofing will ensure that all supervisors, superintendents, and other on-site supervisory personnel know and carry out our obligation to maintain such a working environment, with specific attention to minority and female individuals working at such sites or in such facilities.
· Establish and maintain a current list of minority and female recruitment sources, provide written notification to minority and female recruitment sources and community organizations when Blackhawk Roofing or its unions have employment opportunities available, and maintain a record of the organization’s responses.
· Maintain a current file of the names, addresses, and telephone numbers of each minority and the female off-the-street applicant and minority or female referral from a union, a recruitment source, or a community organization and document any actions taken concerning each such individual. If an individual was sent to the union hiring hall for referral and was not referred back to Blackhawk Roofing by the union or, if referred, not employed by Blackhawk Roofing, this shall be documented in the file with the reason therefore, along with whatever additional actions Blackhawk Roofing, LLC may have taken.
· Provide immediate written notification to the Director when the union or unions with which Blackhawk Roofing, LLC has a collective bargaining agreement has not referred a minority person or woman sent by Blackhawk Roofing or when Blackhawk Roofing has other information that the union referral process has impeded Blackhawk Roofing’s efforts to meet its obligations.
· Develop on-the-job training opportunities and/or participate in training programs for areas expressly including minorities and women by upgrading existing programs and apprenticeship and trainee programs relevant to Blackhawk Roofing’s employment needs, especially those programs funded or approved by the Department of Labor. Blackhawk Roofing shall provide notice of such programs to the sources compiled above.
· Disseminate our EEO policy by providing notice of the policy to unions and training programs and requesting their cooperation in assisting Blackhawk Roofing in meeting our EEO obligations; by including it in any policy manual and collective bargaining agreement; by publicizing it in the annual report, advertisements, etc.; by specific review of the policy with all management personnel and with all minority and female employees at least once a year; and by posting the company EEO policy on bulletin boards accessible to all employees at each location where construction work is performed.
· Review, at least annually, Blackhawk Roofing’s EEO policy and affirmative action obligations under contract specifications with all employees having any responsibility for hiring, assignment, layoff, termination, or other employment decisions, including specific review of these items with onsite supervisory personnel such as superintendents, foremen, etc., before the initiation of construction work at any job site. A written record shall be made and maintained identifying the time and place of these meetings, the persons attending, the subject matter discussed, and the disposition of the subject matter.
· Disseminate Blackhawk Roofing’s EEO policy externally by including it in any advertising in the news media, specifically including minority and female news media, and providing written notification to and discussing the policy with other Contractors and Subcontractors with whom Blackhawk Roofing does or anticipates doing business.
· Direct oral and written recruitment efforts to minority, female, and community organizations, schools with minority and female students, and to minority and female recruitment and training organizations serving our recruitment area and employment needs. Not later than one month before the date for the acceptance of applications for apprenticeship or other training by any recruitment source, Blackhawk Roofing shall send written notification to organizations such as the above, describing the potential openings, screening procedures, and tests (if any) to be used in the selection process.
· Encourage present minority and female employees to recruit other minority persons and women and, where reasonable or within the law, provide after-school, summer, and vacation employment to minority and female youth both on the site and in other areas of Blackhawk Roofing’s workforce.
· Validate all tests and other selection requirements where there is an obligation to do so under 41 CFR Part 60-3.
· Conduct, at least annually, an inventory and evaluation of all minority and female personnel for promotional opportunities and encourage these employees to seek or prepare for such opportunities through appropriate training, etc.
· Ensure that seniority practices, job classifications, work assignments, and other personnel practices do not have a discriminatory effect by continually monitoring all personnel and employment-related activities to ensure that the EEO policy and Blackhawk Roofing’s obligations under contract specifications are being carried out.
· Ensure that all facilities and company activities are non-segregated except that separate or single-user toilets and necessary changing facilities shall be provided to assure privacy between the sexes.
· Document and maintain a record of all solicitations of offers for subcontracts from minority and female construction contractors and suppliers, including circulation of solicitations to minority and female contractor associations and other business associations.
· Conduct a review, at least annually, of all supervisors' adherence to and performance under Blackhawk Roofing’s EEO policies and affirmative action obligations.