Trinity Operating Procedures - TOPs

TOP-EEOAA: Equal Employment Policy & Affirmative Action Plan

Rev: 12/06/2017

Scope: Trinity Forge & Machine (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.

Procedure:

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 HR Manager has equal employment opportunity responsibilities.

II. IDENTIFICATION OF ORGANIZATIONAL UNITS

Trinity Forge operates a forging and machining department in Mansfield, Texas. As of July 1, 1993, only one employee did not work directly in Mansfield, a Sales Representative 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 HR 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.

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. Officers -- as a Board-appointed officials of Trinity Forge, have the overall responsibility for the effective development and implementation of the Equal Employment Opportunity policy. The Officers have the full support of the Board of Directors 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 Resources (HR) Manager -- has the day-to-day responsibilities for the implementation of the policy, accountable to the VP-Manufacturing. As the manager with equal employment responsibilities, the HR Manager has the full support of the Board of Directors, the officers 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 HR 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 HR 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 upper management, updating the Affirmative Action Program.
E. Informing upper 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 HR 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 HR Manager.
C The HR 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 HR Manager is responsible for gathering further information as necessary and for coordinating with the officers 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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