Trellis For Tomorrow Policies and Disclosures

EQUAL OPPORTUNITY
IS THE LAW


It is against the law for this recipient of Federal financial assistance to discriminate on the following
bases:


Against any individual in the United States, on the basis of race, color, religion, sex, national
origin, age, disability, political affiliation or belief; and

Against any beneficiary of programs financially assisted under Title I of the Workforce
Innovation and Opportunity Act (WIOA), on the basis of the beneficiary’s citizenship/status as a
lawfully admitted immigrant authorized to work in the United States, or his or her participation
in any WIOA Title I-financially assisted program or activity.


The recipient must not discriminate in any of the following areas:


Deciding who will be admitted, or have access, to any WIOA Title I-financially assisted
program or activity; Providing opportunities in, or treating any person with regard to, such a
program or activity; or


Making employment decisions in the administration of, or in connection with, such a program
or activity.


WHAT TO DO IF YOU BELIEVE

YOU HAVE EXPERIENCED DISCRIMINATION


If you think you have been subjected to discrimination under a WIOA Title I-financially assisted
program or activity, you may file a complaint within 180 days from the date of the alleged violation
with either:


The recipient’s Equal Opportunity Officer (or the person whom the recipient has designated for
this purpose); or

The Director, Civil Rights Center (CRC), U.S. Department of Labor, 200 Constitution Avenue
NW, Room N-4123, Washington, DC 20210

If you file your complaint with the recipient, you must wait either until the recipient issues a
written Notice of Final Action, or until 90 days have passed (whichever is sooner), before filing
with the Civil Rights Center (see address above.)

If the recipient does not give you a written Notice of Final Action within 90 days of the day on
which you filed your complaint, you do not have to wait for the recipient to issue that Notice
before filing a complaint with the CRC. However, you must file your CRC complaint within 30
days of the 90-day deadline (in other words, within 120 days after the day on which you filed
your complaint with the recipient).

If the recipient does give you a written Notice of Final Action on your complaint, but you are
dissatisfied with the decision or resolution, you may file a complaint with the CRC. You must
file your CRC complaint within 30 days of the date on which you received the Notice of Final
Action.


FOR INFORMATION OR TO FILE A COMPLAINT, CONTACT


Equal Opportunity Officer, Jeannette M. Roman,
jroman@chesco.org
Chester County Workforce Development Board

Chester County Department of Community Development

601 Westtown Road, Suite 365, West Chester, PA 1938

ANTI HARASSMENT AND DISCRIMINATION POLICY

This policy applies to all work-related settings and activities, whether inside or
outside the workplace, and includes business trips and business-related social
events. Trellis for Tomorrow’s property (e.g. telephones, copy machines, facsimile
machines, computers, and computer applications such as e-mail and Internet
access) may not be used to engage in conduct that violates this policy. Trellis for
Tomorrow’s policy against harassment covers employees and other individuals who
have a relationship with Trellis for Tomorrow which enables the organization to
exercise some control over the individual’s conduct in places and activities that
relate to Trellis for Tomorrow’s work (e.g. directors, officers, contractors, vendors,
partners, program participants, volunteers, etc.).

Discrimination Is Prohibited


      Trellis for Tomorrow (“The Company”), is an equal opportunity organization
and makes all employment/volunteer/program acceptance decisions without regard
to race, religion, color, sex (including pregnancy, sexual orientation, and gender
identity), national origin, disability, age, genetic information, or any other status
protected under applicable federal, state, or local laws. This policy applies to all
terms and conditions of employment/volunteering/program acceptance, including
but not limited to, hiring, placement, promotion, termination, layoff, recall,
transfer, leaves of absence, benefits, compensation, and training. We seek to
comply with all applicable federal, state, and local laws related to discrimination and
will not tolerate the interference with the ability of any of the Company’s employees
and volunteers to perform their job duties on the basis of discrimination.


      The Company makes decisions concerning employment/volunteering based
strictly on an individual’s qualifications and ability to perform the job under
consideration, the comparative qualifications and abilities of other applicants, and
the individual’s past performance within the organization.


      If you believe that a decision has been made that does not conform with the
organization’s commitment to equal opportunity, your complaint will be promptly,
thoroughly, and impartially investigated. There will be no retaliation against anyone

who files a complaint in good faith, even if the result of the investigation produces
insufficient evidence to support the complaint,

Americans with Disabilities Act

      The Federal Americans with Disabilities Act (ADA) prohibits discrimination
against qualified individuals with disabilities in application procedures, hiring, firing,
advancement, compensation, fringe benefits, job training and other terms,
conditions and privileges of employment. The ADA does not alter the Company’s
right to secure the best-qualified applicant, but it does prohibit discrimination
against a qualified applicant or employee/volunteer because of his or her disability,
or because of a perceived disability. As a matter of Company policy, the Company
prohibits discrimination of any kind against people with disabilities.

Disabled Defined


      An applicant or employee/volunteer is considered disabled (as defined by the
Federal Americans with Disabilities Act) if he or she (1) has a physical or mental
impairment that substantially limits one or more major life activities; (2) has a
record or past history of such an impairment; or (3) is regarded or perceived
(correctly or incorrectly) as having such impairment.

       A qualified employee/volunteer or applicant with a disability is an individual
who satisfies the requisite skill, experience, education, and other job-related
requirements of the position held or desired, and who, with or without reasonable
accommodation, can perform the essential functions of that position.

Reasonable Accommodation


      A reasonable accommodation is any change in the work environment (or in
the way things are usually done) to help a person with a disability apply for a job,
perform the duties of a job, or enjoy the benefits and privileges of employment.

     

      Qualified applicants or employees/volunteers/participants who are disabled
should request reasonable accommodation from the Company in order to allow
them to perform a particular job. If you are disabled and you desire such
reasonable accommodation, the request is to be put in writing to the Executive
Director. On receipt of your request a representative of the Company will meet with
you to discuss your disability. The Company may ask for information from your
health care provider(s) regarding the nature of your disability and the nature of
your limitations or take other steps necessary to help us determine viable options
for reasonable accommodation. The Company will then work with you to determine
whether your disability can be reasonably accommodated, and if it can be
accommodated, the Company will explore alternatives with you and endeavor to
implement a mutually agreeable accommodation.

      Reasonable accommodation may take many forms and it will vary from one
employee/volunteer/participant to another. Please note that according to the ADA,

the Company does not have to provide the exact accommodation you want, and if
more than one accommodation works, the Company may choose which one to
provide. Furthermore, the Company does not have to provide an accommodation if
doing so would cause undue hardship to the Company.

Harassment


      The Company is committed to providing an environment that provides
employees/volunteers equality, respect, and dignity. In keeping with this
commitment, the Company has adopted a policy of “zero tolerance” with regard to
harassment. Harassment is defined under federal law as unwelcome conduct that is
based on race, color, religion, sex (including pregnancy, sexual orientation, and
gender identity), national origin, age (40 or older), disability or genetic information.
Harassment becomes unlawful where: (1) enduring the offensive conduct becomes
a condition of continued employment/volunteering; or (2) the conduct is severe or
pervasive enough to create an environment that a reasonable person would
consider intimidating, hostile, or abusive.


      Depending on the circumstances, the following conduct may constitute
discriminatory harassment: (1) epithets, slurs, negative stereotyping, jokes, or
threatening, intimidating, or hostile acts that relate to a protected characteristic;
and (2) written or graphic material that denigrates or shows hostility toward an
individual or group because of a protected characteristic and that is circulated in the
workplace, or placed anywhere in Trellis’ premises such as on an employee’s desk
or workspace or on the organization’s equipment, bulletin boards, internal
applications, social media, website, or other. Other conduct may also constitute
discriminatory harassment if it falls within the definition of discriminatory
harassment set forth above.


      This policy applies to all terms and conditions of
employment/volunteering/program participation. Harassment of any other person,
including, without limitation, fellow employees/volunteers, contractors, visitors,
participants, partners, clients or customers, whether at work or outside of work, is
grounds for immediate termination. The Company will make every reasonable effort
to ensure that its entire community is familiar with this policy and that all are aware
that every complaint received will be promptly, thoroughly and impartially
investigated and resolved appropriately. The Company will not tolerate retaliation
against anyone who complains of harassment or who participates in an investigation.

Sexual Harassment


      Sexual harassment is prohibited by federal, state and local laws, and applies
equally to men and women. Federal law defines sexual harassment as unwelcome
sexual advances, requests for sexual favors and other verbal or physical conduct of
a sexual nature when the conduct: (1) explicitly or implicitly affects a term or
condition of an employee’s/volunteer’s company relationship; (2) is used as the
basis for decisions affecting the employee/volunteer; or (3) unreasonably interferes
with an employee’s/volunteer’s work performance or creates an intimidating, hostile
or offensive environment.


      Such conduct may include but is not limited to: subtle or overt pressure for
sexual favors; inappropriate touching; lewd, sexually oriented comments or jokes;
foul or obscene language; posting of suggestive or sexually explicit posters,
calendars, photographs, graffiti, or cartoons; and repeated requests for dates.
Company policy further prohibits harassment and discrimination based on sex
stereotyping. (Sex stereotyping occurs when one person perceives a man to be
unduly effeminate or a woman to be unduly masculine and harasses or
discriminates against that person because he or she does not fit the stereotype of
being male or female.)


Depending on the circumstances, the following conduct may also constitute sexual
harassment:


      (1) use of sexual epithets, jokes, written or oral references to sexual
conduct, gossip regarding one’s sex life; (2) sexually oriented comments on an
individual’s body, about an individual’s sexual activity, deficiencies, or prowess; (3)
displaying sexually suggestive objects, pictures, and/or cartoons; (4) unwelcome
leering, whistling, or deliberate brushing against the body in a suggestive manner;
(5) sexual gestures or sexually suggestive comments; (6) inquiries into one’s
sexual experiences; or (7) discussion of one’s sexual activities.


      While such behavior, depending on the circumstances, may not be severe or
pervasive enough to create a sexually hostile work environment, it can nonetheless
make co-workers uncomfortable. Accordingly, such behavior is inappropriate and
may result in disciplinary action up to and including termination, regardless of
whether the behavior is deemed to be unlawful.


      The Company encourages reporting of all perceived incidents of sexual
harassment, regardless of who the offender may be. Every employee is encouraged
to raise any questions or concerns with the Executive Director.


Supervisors’ Responsibilities


      All managers are expected to ensure a work environment free from sexual and
other Harassment. They are responsible for the application and communication of
this policy within their work area. Managers should:

        • Create a work environment where sexual and other harassment is not
permitted.

        • Encourage employees to report any violations of this policy before the
harassment becomes severe or pervasive.


Procedures for Reporting and Investigating Harassment


      Employees/Volunteers/Program Participants should report incidents of
inappropriate behavior or sexual harassment as soon as possible after the
occurrence. Regardless of whether the offensive act was committed by a manager,
co-worker, vendor, visitor, fellow volunteer, or client, you should notify the offender
that his or her behavior is unwelcome; or, notify the Executive Director. The
Executive Director will then attempt to resolve the situation as promptly and
discretely as possible. If the complaint is against the Executive Director, the
employee should contact the President of the Board of Directors.


      Every claim of harassment will be treated seriously, no matter how trivial it
may appear. All complaints of harassment, sexual harassment, or other
inappropriate sexual conduct will be promptly, thoroughly, and impartially
investigated by the Company.


      There will be no retaliation for filing or pursuing a harassment claim. To the
extent possible, all complaints and related information will remain confidential
except to those individuals who need the information to investigate, educate, or to
take action in response to the complaint.


      All employees/volunteers are expected to cooperate fully with any ongoing
investigation regarding a harassment incident. Employees/volunteers who believe
they have been unjustly charged with harassment can defend themselves verbally
or in writing at any stage of the investigation.


      To protect the privacy of persons involved, confidentiality will be maintained
throughout the investigatory process to the extent practicable and appropriate
under the circumstances. Investigations may include interviews with the parties
involved, and where necessary, individuals who may have observed the alleged
conduct or who may have relevant knowledge.


      At the conclusion of a harassment investigation, the complainant and the
“alleged harasser” shall be informed of the determination. Where appropriate, the
“harasser” and the “victim” may be offered mediation or counseling.


Penalties for Violation of Anti-Harassment Policy


      If it is determined that inappropriate conduct has occurred, the Company will
act promptly to eliminate the offending conduct, and take such action as is
appropriate under the circumstances. Such action may range from counseling to
termination of employment/volunteer arrangement, and may include such other

forms of disciplinary action, as the Company deems appropriate under the
circumstances and in accordance with applicable law.


      While it is not the purpose of this Policy to regulate an employee’s personal
morality, the Company considers harassment, discrimination, or retaliation to be an
act of misconduct and subject to appropriate disciplinary action, up to and including
termination of employment. False and malicious complaints of harassment,
discrimination or retaliation may be the subject of appropriate disciplinary action.
On the other hand, an employee will not be disciplined merely because the
complaint is found to be without merit. Trellis for Tomorrow does not condone
retaliation against any employee for making a report in good faith under this Policy.

Approved May 2021


P ARTICIPANT RIGHTS AND GRIEVANCE PROCEDURES


As a participant in a federally funded program, you are guaranteed certain rights by law. You
should receive the same fair and equal treatment as any other person participating in a similar
work or training situation. If you feel your rights to equal employment are being denied, you are
encouraged to discuss this with your immediate Case Manager or Program Instructor. In
particular, you should immediately report any discriminatory action taken against you on the
basis of your race, creed, color, national origin, sex, religion, age, political affiliation or belief or
handicap.


If, after you have done this, you do not feel the situation has been corrected, you should contact
the EO/AA Officer of the Chester County Department of Community Development, the local
Workforce Development Area Office at (610) 344-6900. The EO/AA Officer will review the
situation and, if necessary, assist you in filing a formal grievance. In the event that you don’t
feel comfortable contacting the EO/AA Officer, you should contact your Program Instructor,
DCD Case Manager, CAO Caseworker or the DCD Deputy Director for further assistance.


Complaint and Grievance Procedure


Within one year (except for fraud or criminal activity) from the alleged commission of a violation
(180 days for complaints alleging discrimination because of a handicap), any WIOA or TANF
Program Participant, staff member, subcontractor, or other interested party shall have the right
to file a complaint with the DCD and receive fair and impartial processing of the complaint,
according to the following procedures:


Filing of Complaints: Any aggrieved party shall first be required to meet with the designated
representative of the subcontractor, their Case Manger, CAO Caseworker, or Program
Instructor.


If this fails to resolve the issue, within five days, the complainant shall submit the complaint in
writing to the DCD, to the attention of the AA/EO Officer or Deputy Director and request an
informal conference. At a minimum the written complaint should include:


-the name and address of the complainant,

-the name and address of the person/agency charged with the violation,

-the reason for the complaint, and

-the date and time of the violation.


Within forty-eight (48) hours of the receipt of a written complaint, the EO/AA Officer will inform
the person(s) or agency charged, of the receipt of the complaint.


Opportunity For An Informal Conference: Within ten (10) days of the receipt of the written
request for an informal conference, the AA/EO Officer will convene the conference. During this
meeting the AA/EO Officer will attempt to resolve the issue informally. The AA/EO Officer’s
findings will be submitted to the complainant no later than ten (10) days following the
conference.


Opportunity For A Hearing: If the complainant is not satisfied with the results of the informal
conference, he/she must inform the AA/EO Officer (within five (5) days of receiving the AA/EO
Officer’s findings), and may request a hearing, (to be held within thirty (30) days from the date
the complaint was filed), before an impartial judge, to be appointed by the DCD. Those
individuals involved will be notified in writing of the date, time and place of the hearing. Both
parties may utilize legal counsel and may produce appropriate witnesses and records. Within
sixty (60) days of the filing of the complaint, a written decision will be issued by the hearing
officer.


Notice Of Recourse: If the complainant is still dissatisfied, within ten (10) days of the receipt of
the hearing officer’s written decision, he/she may request a review by the appropriate state
agency:


Pennsylvania Department of Labor and Industry,

Bureau of Workforce Development Partnership

Harrisburg, PA


and/or


Department of Public Welfare

Harrisburg, PA

Either of these agencies will review the case and issue a decision within thirty (30) days. Their
decision will be final.

Download File To Fill Out

Chester County Workforce Development Board
Government Services Center
601 Westtown Road, Suite 365

PO Box 2747

West Chester, PA19380-0990

phone (610) 344-6900fax    (610) 344-6925

email:
ccdcd@chesco.org
website: www.chesco.org/ccdcd

Acknowledgement of Sexual Harrasment Policy

I herby certify that I have received, read and understand the sexual harassment policy and my
rights as a Participant of the program and acknowledge so with my signature.


All Career Corps Program staff and program participants must be aware of the individual assigned the
responsibility for ensuring that the work place and program locations are free from sexual harassment
and responsible for investigating complaints of sexual harassment. Program participants can find this
information in their participant handbook.


Complaints may be filed with your local contact listed below:

• Lila Singleton, Chester County WIOA, Chester County Department of Community Development,
601 Westtown Road, Suite 365, West Chester, PA 19380, Phone number: (610) 344-6900:
Extension: 6914


      Additionally, complaints may be filed with any of the agencies listed below:

Within 180 Days of the Incident Within 300 Days of the Incident Additional Resource
PA Human Relations Commission
301 Chestnut Street, Suite 300

Harrisburg, PA 17105-3145

Phone: 717-787-4410

Fax: 717-214-0584

TDD: 717-787-727
Equal Employment Opportunity
Commission

Bourse Building, Suite 400

21 South 5th Street

Philadelphia, PA 19105-2515

Phone: 215-440-2600

Fax: 215-440-2604
Bureau of Equal Opportunity
Department of Public Welfare

Room 223

Health & Welfare Building

Harrisburg, PA 17120

Phone: 717-787-1127

Download File to Fill

Chester County Workforce Development Board
Government Services Center
601 Westtown Road, Suite 365

PO Box 2747

West Chester, PA19380-0990

phone (610) 344-6900fax    (610) 344-6925

email:
ccdcd@chesco.org
website: www.chesco.org/ccdcd

Acknowledgement of Participant Civil Rights

I herby certify that I have received, read and understand my “Civil Rights” as a
Participant of the program and acknowledge so with my signature.


WHAT TO DO IF YOU BELIEVE YOU HAVE EXPERIENCED DISCRIMINATION
If you think that you have been subjected to discrimination under a WIA Title I-financially assisted
program or activity, you may file a complaint within 180 days from the date of the alleged violation with
either:

The recipient’s Equal Opportunity Officer (or the person whom the recipient has designated for
this purpose); or

The Director, Civil Rights Center (CRC), U.S. Department of Labor, 200 Constitution Avenue NW,

Room N-4123, Washington, DC 20210. Voice: (202) 693-6502 TTY (202) 693-6515
If you file your complaint with the recipient, you must wait either until the recipient issues a written Notice
of Final Action, or until 90 days have passed (whichever is sooner), before filing with the Civil Rights
Center (see address above)

Download File to Fill