Equal Employment Opportunity Policy

Federal law-aligned EEO policy prohibiting discrimination in hiring, promotion, compensation, and termination. Required for all U.S. employers with 15+ employees under Title VII; recommended for all sizes.

Purpose

• This policy establishes the organization's commitment to equal employment opportunity and non-discrimination in all employment practices. It is intended to comply with **Title VII of the Civil Rights Act of 1964** and related Equal Employment Opportunity Commission (EEOC) guidance, and to provide a clear process for reporting and addressing concerns. The policy applies to decisions involving hiring, promotion, compensation, training, discipline, assignment, benefits, leave, and termination.

Scope

• This policy applies to all employees, applicants, interns, temporary workers, contractors, and other individuals performing work on behalf of the organization, to the extent permitted by law. **U.S. employers with 15 or more employees:** Title VII generally applies to covered employers. Smaller employers may adopt this policy as a best practice and may still be subject to state or local anti-discrimination laws.

Definitions

• **Protected characteristics:** Traits protected by law from discrimination, including race, color, religion, sex (including pregnancy, sexual orientation, and gender identity), national origin, age, disability, and genetic information, as applicable under federal, state, and local law. **Discrimination:** Unfavorable treatment in an employment decision because of a protected characteristic. **Reasonable accommodation:** A change to a job, work environment, or application process that enables a qualified individual to perform an essential function or participate in the process, unless doing so would create undue hardship. **Retaliation:** Adverse action taken because an individual reported a concern, participated in an investigation, requested accommodation, or otherwise engaged in protected activity.

Policy Statement

• The organization prohibits discrimination, harassment, and retaliation in all employment-related decisions and workplace interactions. Employment decisions must be based on legitimate business factors such as qualifications, performance, skills, experience, conduct, attendance, and business needs. Protected characteristics must never be used as a basis for hiring, promotion, compensation, discipline, scheduling, assignment, training, or termination decisions. Managers and supervisors must apply standards consistently, document performance and conduct concerns, and avoid assumptions or stereotypes related to protected characteristics.

Procedure

• 1. **Reporting concerns:** Employees, applicants, and other covered individuals should report suspected discrimination, harassment, or retaliation to HR, a manager, or another designated contact as soon as possible. 2. **Good-faith review:** The organization will review complaints in good faith, promptly, and as confidentially as practicable. 3. **Investigation:** HR or another designated investigator will gather relevant information, interview witnesses as appropriate, and document findings. 4. **Reasonable accommodation requests:** Individuals seeking accommodation should notify HR or their manager and provide any requested supporting information. The organization will engage in an interactive process to determine whether a reasonable accommodation can be provided. 5. **Outcome and follow-up:** Where a policy violation is found, the organization will take corrective action, which may include coaching, a documented warning, a PIP, reassignment, suspension, or termination, depending on the severity of the conduct. 6. **No retaliation:** Retaliation for raising a concern or participating in an investigation is prohibited, even if the complaint is not substantiated.

Roles & Responsibilities

• **Employees:** Treat others respectfully, report concerns promptly, cooperate in investigations, and avoid retaliation. **Managers and supervisors:** Make employment decisions based on job-related criteria, escalate complaints immediately, preserve confidentiality to the extent possible, and consult HR before taking adverse action involving a protected characteristic or accommodation request. **HR / People Operations:** Maintain the policy, receive and investigate complaints, coordinate the interactive process, document outcomes, and ensure consistent application of corrective action. **Policy holder / leadership:** Support enforcement of the policy, allocate resources for training and investigations, and ensure the policy is reviewed and updated on schedule.

Compliance, Discipline, and Non-Retaliation

• Violations of this policy may result in corrective action up to and including termination of employment or contract, subject to applicable law and any required due process. The organization will not retaliate against any individual who, in good faith, reports a concern, requests an accommodation, participates in an investigation, or otherwise exercises rights protected by law. Managers who fail to report concerns, mishandle complaints, or make discriminatory decisions may be subject to discipline, including removal from supervisory duties.

Exceptions and Jurisdiction-Specific Carve-Outs

• **State and local law overlays:** This policy must be applied in conjunction with applicable state and local anti-discrimination laws, which may provide broader protected classes or additional remedies. **California employees:** Review this policy alongside California Fair Employment and Housing Act (FEHA) requirements and any applicable training obligations. **New York employees:** Review this policy alongside the New York State Human Rights Law and any local human rights ordinances. If a conflict exists between this policy and applicable law, the law controls.

Review & Revision

• This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, or local law, EEOC guidance, and organizational practices. Version history and revisions should be documented by HR or the policy holder.