HomeMy WebLinkAboutMinority Construction Employment PlanCOLUMBUS OFFICE TOWER
MAJOR USE SPECIAL PERMIT
MINORITY CONSTRUCTION
EMPLOYMENT PLAN
•
COLUMBUS OFFICE TOWER
MIAMI, FLORIDA
MINORITY PARTICIPATION PLAN
Hardin fully- endorses the concept of employing and using minority and woman --owned business
enterprises on our projects. Our i\l/WBE programs have greatly impacted the local communities by
creating jobs and providing training to both companies and labor.
Through the use of specifically developed methods, Hardin has successfully met, and in many
cases exceeded, its commitments in providing minority and local participation on our projects.
These methods to target the specific needs of the minority and local contracting communities have
been continually refined through our many years of working with minority and local programs.
Hardin's continued success as a regional contractor is partially due to our ability to maximize both
minority and local participation on all of our projects. We understand that the employment and use of
local contractors and suppliers greatly benefits the entire community. IIardin accomplishes this aim by
allowing such businesses the opportunity to participate in the construction process at all contractualler�eh-,
thus enriching their experience and enhancing their potential for future work.
"Though many- of our projects did not mandate specific goals, our work with M/WBE and local firms
mirrors our commitment to broadening the construction community and returning benefits to the
project's local economy. Ilardin has continually demonstrated this commitment and ability to achieve
local participation. Hardin brings the expertise to solicit, employ and manage such enterprises in a
manner that benefits not only the minority* and Local contractors, but the project as well.
Past Initiatives Undertaken
Hardin has undertaken many successfully initiatives to assist both minority and local firms, including:
• Packaging work items that take advantage of the strengths of the minority and local
contracting community.
• Providing methods for joint check. purchasing to alleviate cash flow problems.
• Waiving of certain insurance limit requirements where excessive limits hinder open
competition.
• Making bidding documents available at convenient locations and times.
• Assisting with bidding preparation.
Page 1
•
•
•
IN.
• Awarding of work items on unit cost basis or rate schedule basis.
• Coordinating with Owners for utilization of their direct purchase procedures of materials to
relieve financial burden on small minority and local subcontractors.
• Assisting with bonding company relations.
• Assisting with procurement of insurance.
• Consideration of labor only contracts to reduce financial burdens.
• Consideration of bidding preferences.
• Actively "going to the source" to solicit subcontractors, especially minority subcontractors.
• Providing training in procedures that are essential to performance of the work.
• Developing mentoring relationships for minority subcontractors.
• Specifying specific minority percentage goals by individual prime subcontract package.
• Developing workshops to keep the targeted bidders aware of the progress of the project,
and thereby allow them to better plan for their participation.
Hardin will develop the suitable initiatives from among those mentioned above in combination with
new initiatives, as appropriate, to help facilitate local participation.
Ilardin will ensure that both local and minority businesses will have an equitable opportunity to
compete for subcontracts and material purchase orders. Our many years of experience in developing
and instituting this type of program has shown to us that both local and MBE participation programs
have a key common ingredient - providing significant opportunity to the taxpayer base. Our
Participation Program outlined below, recognizes that this common goal of providing opportunity
creates methodological similarities to achieving local and minority participation, yet recognizes the
unique differences encountered. between working with local, minority, and majority contractors.
The following outlines our Program, and addresses the similarities and differences between each facet
of the minority and local participation:
Definition of Minority Goal
The goal of Hardin's Minority .Program is to obtain participation of minority owned businesses, without
incurring any additional cost or additional time. A major component of this goal is that all minority
companies improve their contracting abilities in some manner by the proect's completion.
Definition of Local Goal
It is the goal of the project to maximize the ability of the local construction community to participate in.
the competition for the work, and in the work itself, thereby returning the benefits of the
construction expenditures to the local community to the maximum extent possible. This goal is to
be implemented at every contractual level in the construction process.
Page 2
•
HAMM.
Responsibility
Hardin has designated a Program Liaison, who will serve as the focal point of the program and who
will coordinate to ensure the following:
A. The Program is clearly defined and represents I-Iardin's and the Owner's goals_
B. The appropriate staff and effort is dedicated to the Program.
C. The overall Program is properly- implemented.
D. The appropriate parties are periodically informed and updated on the Program status
While ensuring that the Program goals are being met, it will also be the Liaison's responsibility to
perform the actual implementation of the program. Duties include:
A. Recruiting minority and local participation.
B. I?valu.ating qualifications and appropriate certifications of proposed minority and local
participants.
C. valuating proposals to ensure that proper response to the minority goals have been met.
D. Assisting in providing training to minority firms, where appropriate.
I::.. Maintaining accurate records and documentation.
fi. Coordinating and reporting to appropriate individuals concerning required actions and.
needs.
G. Monitoring and reporting the progress of minority and local participation.
Recruiting Minority Participation
A. Hardin will compile a master list of minority subcontractors and vendors who arc qualified
and interested in performing work on the project. Hardin will maintain this list, updating it
with additional names and information as required.
B. Hardin will encourage minority- participants to recruit other participants.
C. I Iardin will direct recruitment efforts, both oral and written, to selected organizations which
may provide information related to increasing minority participation.
D. Suppliers, manufactures and bidders who are not minority participants will be advised of the
project's minority goals. Non -minority vendors will be encouraged to obtain second tier
and/or joint venture minority participation on their teams.
Page 3
•
•
•
IN
Recruiting Local Participation
The CM project delivery concept, where businesses are prequalified before bidding, allows for
the best opportunity to seriously consider local business involvement. This process will allow
I- Iardin to fully outline the compliance requirements for overall participation goals for each specific
package. INi Iarket studies by 1 Iardin during the final phases of design. will begin to organize the
contracting strategy, which will maximize local business awareness of the opportunities created by the
project.
Monitoring and Reporting
A.
1 Jardin will prepare a preliminary= summary of construction disciplines indicating the
percentage of participation expected to be obtained. 'i'his summary will be expanded in
detail and updated to reflect actual minority participation at each phase of work.
B. Each subcontractor and vendor will be required to submit a summary with each Request for
Payment that reflects their progress in meeting their minority commitments.
C. A periodic minority report will be issued by l-Iardin and will include:
1. Current status of projected versus committed participation.
2. Current status of the minority work performed to date.
3. Program summary that includes any trends that may require action to meet the
committed goals.
The above -outlined Program has been developed by Hardin to ensure that minority participation goals
are clearly established and maintained throughout the project. Other specific criteria and activities will
be added to this framework as the project may require.
Participation on Self -Perform Work
We recognize that the minority and local participation goals are not meant just for the prime
subcontractors, but apply equally to 1:Iardin. We are driven to set an example by maintaining the
same standards for achieving minority and local participation in our self -perform work as those
we require of our subcontractors. We will use time -tested methods to ensure participation for
our selfperform work and general conditions, including:
A. Investigation of strengths of the minority subcontractor and supplier market;
13. Packaging of work to encourage participation;
C. ientoring;
D. Early payment assistance; and
E. Active recruitment of minority employees throughout the range of work to be
performed.
Page 4
•
•
•
„HARDil�sx
Participation at the Sub -Subcontracting and Vendor Levels
Insuring participation at the sub -subcontractor and vendor levels begins prior to the solicitation of
pricing from the prime level. Development of adequate minority goals and standards for each
individual prime subcontract with the Owner will allow introduction of those goals in the bidding
documents with the prime subcontractors. Through taking the time to understand the market for each
of the prime packages, the goals for each can be specifically tailored to take advantage of the strengths
available in the local and minority marketplace. Definition of these goals, then, becomes a requirement
of the bidding process, and is easily monitored for compliance,
Prime contractors will set the appropriate programs in place before tendering their bid. With this
action, the opportunity for compliance increases dramatically. Bids will be specifically reviewed for
meeting the needs of the bid documents, and compliance will be measured throughout the construction
period.
The above --outlined Program has been developed by 1 ardin to ensure that M/WBE participation goals
are clearly established and maintained throughout the project. Other specific criteria and activities will
be added to this framework as the project may recui.re.
Page 5
•
ATTORNEY CLIENT
PRIVILEGED
AFFIRMATIVE ACTION PLAN FOR MINORITIES AND FEMALES
COUSINS PROPERTIES
AFFIRMATIVE ACTION PLAN YEAR SEPTEMBER 1, 2000 - AUGUST 31, 2001
'C»NF'W,F;NTIL 1
Ui!s Af rmafive flalto f'1trn,c ntatns rottfit�errttal c
trtfgrttat#per, urliher prorrleirtrnfortratra.
titr e under 1$' (.' & 1 15 'Ut addi1 o, ,,
�rtnatl4xr Aci pr1Ysu4 fo4empflorr}.
DT SEC M4TERJAL'
N 13 T 1IC�10T $ 5 ] ijllHt ofrszn zg
�rrraf%t1J`Yrade seece ea�tavr�auve C,)rn»xercial'
or
osure b uty gevertretz rIic�la coix3Yu uleral;
ctrr en r xem t jroin d C10$- 'u der 1h reec t'a
�ci5sa,
•
•
•
dpcument alsouliE zzot be retZrouceds rlstributez� yr Shown is Rzzortezthout tJxe pc�rmrssion of G�uszns
2
•
•
I. PREFACE
Cousins Properties ("Cousins") is fully committed to the concept and practice of equal
opportunity and affirmative action in all aspects of employment.
In the preparation of this Affirmative Action Plan, the terminology used in E.O. 11246
and its implementing regulations has been used as a guide by Cousins. Therefore, the use of
such teems as "underutilization," "deficiency," "concentration," "affected class," etc. should
not be construed as an admission by Cousins, in whole or in part, that in fact either minorities
or women have been or are presently being underutilized, concentrated, or discriminated
against in any way by Cousins in violation of federal, state, or local fair employment practice
laws. Furthermore, nothing contained in this Affirmative Action PIan or its supporting data
should be construed as an admission by Cousins, in whole or in part, that it has contravened
such federal, state, or local employment practice laws.
In developing and implementing the Affirmative Action Plan, Cousins has been guided
by its established policy of providing equal employment opportunity. Any goals which
Cousins has established herein are not intended as rigid, inflexible quotas that must be met,
but rather as targets reasonably attainable by applying every good faith effort in implementing
this Affirmative Action Plan. The use of goals in this Affirmative Action Plan is not intended,
nor is the effect of such goals intended, to discriminate against an individual or group of
individuals with respect to any employment opportunities for which he, she, or they are
qualified on the grounds that he, she, or they are not the beneficiaries of affirmative action
themselves. Indeed, nothing herein is intended to sanction the discriminatory treatment of any
person. Thus, this Affirmative Action Plan has been developed in strict reliance upon the
Guidelines on Affirmative Action issued by the Equal Employment Opportunity Commission
(EEOC) (29 C.F.R. Part 1608).
While Cousins firmly believes in wide dissemination of its affirmative action policies
and equal employment opportunity practices, there is certain proprietary information relating
to its business which must be kept confidential. The detailed infonmation provided in good
faith as a part of the Affiiinative Action Plan contains specific information which, if
disseminated, can be detrimental to the competitive and business interest of this company. At
a minimum, the complexity of this data is subject to misinterpretation and misuse which again
can be very harmful to business goals and objectives, solely unrelated to the affirmative action
and equal employment opportunity concept.
3
•
•
Therefore, even though Cousins is justifiably proud of the progress and goals that are
described in the following pages, the following is requested:
A. If this information is submitted to the Office of Federal Contract Compliance
Programs (OFCCP) pursuant to the relevant Executive Order and regulations, it
is to be considered confidential and not subject to disclosure without notifying
Cousins of the agency's decision to disclose and providing Cousins with ample
time to contest the disclosure.
B. If this information is supplied to a government contractor, EEOC
representative, or any other person who is given access to the Affirmative
Action Plan, it is not to be copied, reproduced, or disclosed without prior
notification to Cousins.
C. No information contained in the Affirmative Action Plan is to be copied,
removed from the premises, or released to other individuals without prior
notification to Cousins.
D. All monitoring system reports as required by federal regulations and laws have
been completed. Reports which require specific data such as names of
employees and salary .information have not been included within the context of
this Plan. This information is on file at Cousins as Documentation and
Supporting Data for Affirmative Action Plan Reports and is available for
review only as required by law.
The material set forth in this Affirmative Action Plan is deemed to constitute trade
secrets, operations information, confidential statistical data and other confidential commercial
and financial data, within the meaning of the .Freedom of Information. Act, 5 U.S.C. Section
552, et seq. Title VII of the Civil Rights Act of 1964 (as amended), 42 U.S.C. Sections 2000e
et seq., the Trade Secrets Act, 18 U.S.C. Section 1905, and 44 U.S.C. Section 3508, the
disclosure of which is prohibited by law and may subject the individual making the disclosure
to criminal and/or civil sanctions.
This Affin native Action Plan does not constitute an express or implied contract
between Cousins and its employees, job applicants, or other persons.
4
•
•
1I. COMMITMENT TO EQUAL EMPLOYMENT OPPORTUNITY
[41 C.F.R. §§ 60-1.4;-2.13(01
It has been, and will continue to be, the policy of Cousins Properties to be an equal
opportunity employer. Cousins states as its policy the following:
Cousins will not tolerate or condone unlawful discriminatory practices
in the workplace. Cousins' employees and their work environment should be
free from all fouiis of unlawful harassment, discrimination, and intimidation.
Cousins will make all employment decisions (including decisions about hiring,
promotion, transfer, demotion, evaluation, compensation and termination)
without regard to race, color, national origin, citizenship, sex, pregnancy,
religion, age, disability, service in the uniformed services, citizenship, or any
other classification protected by federal, state or local law.
Because Cousins stands ready to resolve any instance of alleged
discrimination, employees are encouraged whenever they believe there has
been an instance of discrimination, to contact their immediate supervisor. If
the employee is not satisfied with the action taken, he/she may take the
complaint to the next level of management or to Human Resources.
Employees can raise concerns and make reports without fear of retaliation.
Anyone found to be engaging in any type of unlawful discrimination will be
subject to disciplinary action, up to and including termination of employment.
In keeping with this policy, Cousins will continue to recruit, hire, train and promote
into all job Levels the most qualified persons without regard to race, color, religion, sex or
national origin. Similarly, Cousins will continue to administer all other personnel matters
(such as compensation, benefits, transfers, layoffs, company -sponsored training, education,
tuition assistance and social and recreational programs) in accordance with Cousins policy.
Cousins bases employment decisions on objective standards so much as possible in the
furtherance of equal employment opportunity.
Becky Garrigan, Human Resources Manager, has been designated as Cousins'
Affirmative Action Officer. As such, Ms. Garrigan is responsible for the overall
implementation and monitoring of Cousins' comprehensive affirmative action program. All
concerns or questions regarding this policy are to be directed to Ms. Garrigan. Any employee
or applicant raising concerns or questions will not be subject to coercion, intimidation,
retaliation or interference.
T. G. Cousins
Chairman and CEO
Cousins Properties
Effective September I, 2000
5
•
•
•
III. DISSEMINATION OF POLICY
A. Internal Dissemination.
141 C,F_R, §§ 60-2.13(b);-2.21(a)]
Cousins will continue to make its equal employment opportunity policy
known internally by:
a. Including the policy in Cousins' policy manual.
b. Conducting special meetings with executive, management and
supervisory personnel to explain the intent of the policy, the
chief executive officer's attitude, and individual responsibilities
for effective implementation.
c. Explaining the policy thoroughly in employee orientation and
management training programs.
d. Posting the policy on Cousins bulletin boards.
e. Picturing both minority and non -minority men and women in
publications in which employees are featured.
f. Making current employees aware of the existence of Cousins'
affirmative action program_
B. External Dissemination
[41 C.F.R. §§ 60-2.13(b);-2.21(b)]
Cousins will continue to disseminate its policy externally by:
a. Informing all recruiting sources verbally and in writing of
Cousins' policy, stipulating that these sources actively recruit
and refer minorities and women for all positions listed.
b. Incorporating Cousins' equal opportunity policy in all purchase
orders and contracts covered by Executive Order 11246, as
amended.
6
•
•
•
c. Notifying in writing minority and women's organizations,
community agencies, community leaders, secondary schools and
colleges, of Cousins' policy, as appropriate.
d. Informing prospective employees of the existence of Cousins'
affirmative action program.
e. Sending written notification of Cousins policy to all "covered"
subcontractors, vendors, and suppliers retained in conjunction
with Cousins' work as a covered federal subcontractor
requesting appropriate action on their part, where appropriate.
7
•
•
•
IV. RESPONSIBILITY FOR IMPLEMENTATION
[41 C P.R. §§ 60-2.13(c); -2.111
Cousins has assigned coordination of responsibilities to implement the policy to Becky
Garrigan, Human Resources Manager, who has the full support of executive management.
1. Duties of the Affirmative Action Officer
[41 C.F.R.. § 60-2.72(a)(1-7)]
The duties of the Affirmative Action Officer include:
a. Developing policy statements, affttmative action programs and
internal and external communication techniques.
b. Identifying problem areas.
c. Assisting appropriate personnel in arriving at solutions to
problems.
d. Working with attorneys to design and implement auditing and
reporting systems that:
(1) Measure the effectiveness of Cousins EEO programs.
(2) Indicate any need for remedial action.
(3)
Determine the degree to which Cousins' goals and
objectives are being attained.
e. Serving as liaison between Cousins, counsel, and enforcement
agencies.
£ Serving as liaison between Cousins and minority organizations,
women's organizations and community action groups concerned
with employment opportunities of minorities and women.
g.
Keeping management informed of the latest developments in the
equal opportunity area.
8
•
•
h. Meeting with appropriate personnel to make certain that
Cousins' EEO policies are being followed.
i. Informing all supervisors that their individual work performance
is being evaluated on the basis of the equal employment
opportunity efforts and results, as well as other criteria.
9
•
•
•
V. WORKFORCE ANALYSIS
[41 C.F.R. § 60-2.11(a)]
As of August 31, 2000 Cousins employed approximately 530 employees. Because this
is Cousins' first formal affiimative action plan, it did not previously keep record of all of the
required information needed to complete this plan on each employee. Cousins surveyed its
workforce with a voluntary questionnaire asking for this information, and was able to gather
the information needed to complete this plan from 333 of its employees. Cousins divides its
workforce into 4 informal departments according to geography as follows:
• Georgia
• Texas
• California
• North Carolina
We have considered different department groupings not reflected here, but ultimately
selected these groupings because of the relative distribution of employees between cities. Any
smaller groupings, or groupings within each city, would dilute the numbers to the point that
any analysis, statistical or otherwise, would be less meaningful. We have displayed within
each department for each job title, the total number of incumbents, the total number of male
and female incumbents, and the total number of male and female incumbents who are White,
Black, Hispanic, American -Indians, Asian, and Other. We reflect these data on the Workforce
Analysis forms which follow:
10
•
•
•
VI. ANALYSIS OF MAJOR JOB GROUPS
[41 C.F.R § 60-2.1I(b)l
Pursuant to 41 C.F.R. § 60-2.11(b), we have supplied below an analysis of all major
Job Groups at Cousins. Specifically, we have grouped those jobs having similar content, wage
rates and opportunities. As a result, we have grouped the company's employees into five Job
Groups, including the following:
• Officials and Managers
• Professionals
• Office and Clerical
• Service
• Technicians
Moreover, in so doing, we have been mindful of the need to keep Job Groups
sufficiently large that they make for meaningful statistical analyses. In addition, we have
avoided placing job titles from different EEO-1 categories within the same Job Group,
wherever possible. Finally, while we have considered different job groupings not reflected
here, we have rejected those alternatives because they do not make a substantial difference and
do not mask any potential underutilization of minorities or women. We have reflected our
analysis of the major Job Groups on the Availability Analysis foinis which follow.
11
•
•
•
VIL AVAILABILITY ANALYSIS
The following Availability Analysis estimates the percentages of minorities and
women available for employment in each identified Job Group and compares calculated
availability percentages with Cousins' actual employment percentages to ultimately identify
potential underutilization of women and minorities_
12
•
•
•
VIIL IDENTIFICATION AND CORRECTION OF PROBLEM AREAS
141 C.F R. §§ 60-2.13(d); -2.23]
A. We have made a detailed analysis of the following potential problem areas by
Job Group:
1 Our analysis reveals that, according to the OFCCP's regulations,
minorities are underutilized only in Job Group(s):
• Officials and Managers
• Office and Clerical (although not statistically significant)
Our analysis reveals that, according to the OFCCP's regulations,
females are underutilized only in Job Group(s):
• Service (although not statistically significant)
• Technicians
B. Accordingly, Cousins has established goals for which there is statistically
significant underutilization as defined by the applicable federal regulations.
These goals are neither rigid nor inflexible quotas. Instead, they are objectives
to be pursued by mobilization of available resources for a good faith effort.
Cousins' statistical Affirmative Action Plan Goals are:
1. For job group Technicians, the female percentage goal is 20.00%.
While Cousins maintains a long-teu n goal the achievement of
employment that is equal to availability, it nonetheless has set
reasonably attainable goals for the upcoming year.
2. For job group Officials and Managers, the minority percentage goal is
13.08%, equal to availability.
C. We have established affirmative action goals and programs to correct any
deficiencies as defined by the OFCCP, and we will continue to make a good
faith effort to reach these goals and implement the programs, which are
detailed elsewhere in the Plan. Furthermore, we plan to take the following
additional steps to eliminate any underutilization of all minorities and females:
13
•
•
•
. Where underutilization exists as defined by the OFCCP in the job
groups within the EEO-1 Categories of Officials and Managers and/or
Professionals we will continue to contact universities, and two and four
year local colleges which attract minority and female students when
openings justify. We will advise these institutions of our desire to fill
job openings in these 'classifications with minority and female
employees.
Where underutilization exists as defined by the OFCCP in the job
groups within the EEO-1 categories of Technicians, Office and Clerical,
or Service Workers, we will continue to contact local community
colleges, vocational technical schools, high schools, local business
schools and state and community organizations which attract minority
and female students whenever openings justify. When possible, we will
continue to participate in job fair and career day activities and we may
consider relevant work experience programs.
2. We will continue to contact our normal sources of recruitment and
advise them that under the Affirmative Action Plan we are specifically
seeking to employ minorities and/or women for job openings.
3. We will continue to make opportunities for advancement into more
stimulating positions widely known through our career development
process and by encouraging minorities and females to take advantage of
said opportunities.
D. Total Selection Process
Position descriptions and worker specifications have been developed, reviewed
and revised to ensure that duties are accurately described and that the
experience and education requirements are strictly job related, and position
titles have and will continue to be written without regard to sex, race, or
disability.
Application forms have been reviewed to ensure that all requested information
is job related. The application forms comply with all applicable law. We have
stated on the form that Cousins is an Equal Opportunity Employer. All
interviews are scheduled for qualified and interested applicants without
14
•
•
•
discrimination on the basis of race, sex, or disability but with a recognition of
Cousins' affirmative action obligations. Test administration and use are
conducted in a non-discriminatory mariner.
All employees are encouraged to refer qualified applicants to Cousins for
employment.
Placing an applicant in a specific job in a department is the responsibility of
management. External hiring decisions are based on the applicant's experience
and/or abilities. Internal hiring decisions are made on the basis of the
employee's experience and abilities, and where all other factors are equal,
length of service with Cousins may be considered. All hiring decisions are
made with Cousins' affirmative action obligations in mind.
E. Transfer and Promotion Practices
Employees are encouraged to contact their superior and/or the Human
Resources Department, at any time, should they desire information relative to
another position within their own or some other department.
Management initiated promotions are based solely on performance without
discrimination on account of race, sex, age, national origin, or disability, but
with a recognition of Cousins' affirmative action obligations.
Management initiated transfers are based on job requirements without
discrimination on account of sex, age, national origin, or disability, but with an
appreciation of Cousins' affirmative action obligations.
All of these factors strongly indicate that personnel practices represent an area
of substantial employment opportunity for minority and female employees.
F. Facilities, Cousins Sponsored Recreational and Social Events and Special
Programs
Our analysis of Cousins' facilities and programs reveals that this is not a
problem area for minorities or women in any job group or organizational unit.
Employees are informed of Cousins sponsored social and recreational
activities.
15
•
•
•
G. Seniority Practices and Seniority Provisions of Union Contracts:
This is not a problem area since Cousins has no direct union representation.
H. Apprenticeship Programs:
This is not a problem since Cousins does not participate in apprenticeship
programs and does not offer employment in positions requiring an
apprenticeship.
1. All Cousins Training Programs:
Our analysis of Cousins training programs reveals that this is not a problem
area for minorities or women in any job group or organizational unit. Cousins
offers several on-the-job programs which help employees to increase
qualifications and skills which might lead to advancement. Any other training
is on-the-job applicable to the incumbent's position. On-the-job training is
administered without regard to minority group status or sex, taking into
consideration only the amount of skill and/or familiarity that is already
possessed.
J. Work Force Attitude:
Our analysis of work force attitude reveals that this is not a problem for
minorities and females at Cousins. We believe that our employees are
supportive of our efforts to provide equal employment opportunities. In
addition, employees experiencing work related problems are encouraged to use
lines of open communication through supervisory personnel and/or the Human
Resources Department.
K. Technical Phases of Compliance, such as Posters, Retention of Applications,
Notification to Subcontractors, etc.
Our analysis of the technical phases of compliance reveals that Cousins fully
complies with all the technical phases of its affirmative action obligations:
16
•
•
•
1. Equal Employment Opportunity posters are prominently
displayed in each Cousins location.
2. Cousins does not have any direct Union contracts.
3. Cousins' employment application has a statement concerning
Equal Employment Opportunity.
4. All recruitment agencies and area schools and colleges will
continue to be notified of Cousins' commitment to the goals of
Affirmative Action.
5. All recruitment advertising includes the solicitation: "An Equal
Opportunity Employer" or its abbreviation.
6. A majority of vacancies not expected to be filled from within
are communicated to the State Department of Employment &
Training or America's Job Bank.
7. All other required affirmative action notices and policy
statements are posted on Cousins bulletin boards and are
updated annually.
8. Cousins files a VETS-100 and EEO-1 report annually.
9. All required reporting and EEO clauses are inserted in contracts,
where mandatory.
17
•
•
•
IX. DEVELOPMENT AND EXECUTION OF ACTION -ORIENTED PROGRAMS
[41 C.F.R. § 60-2.13(f); 2.24 (a-h)I
We have developed the following action -oriented programs tailored in such a way that
their proper execution will result either in an increase in the minority group/female
representation in the group and/or organizational units identified, if vacancies occur, or
document our good faith efforts to do so. These efforts may include:
I . Selection Process
a. To the extent that they exist, Cousins has developed and reviewed all
position descriptions within the past year, and has found that they
accurately reflect position functions.
b. Cousins has validated the employee specifications for each job title in
each department using only job performance criteria. These
specifications are nondiscriminatory with respect to race, color,
religion, sex (except where sex is a bona fide occupational
qualification) and national origin. Specifications for a particular job are
consistent in all locations.
c. These validated position descriptions and employee specifications are
available to all members of management involved in the recruiting,
screening, selection and promotion process. Copies of position
descriptions and employee specifications for job openings are available
to all recruiting sources.
d. All other Cousins selection processes have been evaluated and are
nondiscriminatory. All personnel having any part in the selection
processes are chosen with special care and receive ongoing training to
ensure that these processes remain nondiscriminatory.
2. Recruitment
a. Cousins may contact minority and women's organizations for
referrals including, but not limited to, secondary schools and
colleges with high minority enrollment, the State Employment
18
•
•
•
Service, specialized employment agencies, and women's
colleges, as appropriate.
b. Cousins actively encourages all employees including minority
and female employees to refer applicants.
c. Cousins may participate in local "job fairs."
d. Cousins may carry out active recruiting programs at secondary
schools, junior colleges, and colleges with predominantly
minority or female enrollment.
3. Promotions
Cousins may undertake some or all of the following, as necessary, to
ensure that minority and female employees have equal opportunity for all
promotions:
a. Some promotional opportunities are posted or announced.
b. An inventory of the skills, and academic and experience level of
all employees will be developed and maintained.
c. Formal employee evaluation programs are provided for use by
management.
d. Supervisory personnel may be asked to submit written
justification if they do not upgrade seemingly qualified minority
or female employees.
4. Welfare
a. Cousins' facilities and social and recreation activities are
desegregated. All employees are encouraged to participate in
Cousins -sponsored activities.
19
•
A
•
X. REPORTING AND INTERNAL AUDITING SYSTEMS
[41 C.F.R. §§ Go-2,13(g), 60-2.25(a-d)]
As stated previously, the Affirmative Action Officer is responsible for implementing
the auditing and reporting system. S/he monitors this system on a continual basis. The
reporting and auditing system provides for:
1 Maintaining and monitoring accurate and up-to-date records on all
referrals, applicants, hires, promotions, transfers and terminations by
race and sex to be certain that allemployees are treated on a fair and
equitable basis.
2. Reviewing all selection, promotionaland training procedures to ensure
that they are nondiscriminatory.
3. Informing, on a regular basis, top management of the effectiveness of
the policy and recommendations for improvements, if necessary.
4. Ensuring Compliance with all technical and/or ancillary affirmative
action obligation by maintaining a comprehensive checklist.
20
•
•
•
XI. COMPLIANCE WITH SEX DISCRIMINATION GUIDELINES
[41 C.F.R. §§ 60-2.13(h); -20]
It has been and continues to be the policy of Cousins not to discriminate on the basis of
sex. To this end, we continue to do the following:
1 Recruitment and Advertisement.
141 C.F.R. § 60-20.2(a and b)]
a. The company actively recruits both men and women for all jobs.
Referral sources are infoiiiied that Cousins has no specific sex
preference and seeks only qualified applicants without regard to
race, color, sex, religion, or national origin. Recruiting may be
conducted at women's colleges that offer degrees in areas
needed by Cousins.
b. Advertisements, when placed, are put in a general category or,
when a general category is not available, the same advertisement
is placed in both the male and female column with no sex
preference indicated. All advertisements are followed by "Equal
Employment Opportunity."
2. Job Policies and Practices.
141 C.F.R. § 60-20.3(a-h)l
a. The Cousins policies and procedures manual clearly states that
all policies and practices apply to every employee on an equal
basis regardless of the sex of the employee.
b. All employees have equal opportunity for any job for which they
are qualified. Sex is not considered a bona fide occupational
qualification for any job within Cousins.
c. No distinction is made between the sexes in regard to
opportunity, wages, hours, benefits or other conditions of
employment.
21
•
•
or
d. There is no distinction between the employment treatment or
termination of a woman or a man based on marital status. Also,
Cousins does not deny employment to women with young
children, nor does it terminate employees of one sex in a
particular job classification upon reaching a certain age.
e. Cousins provides appropriate and comparable physical facilities
for both female and male employees.
f. Cousins follows federal guidelines relative to employment;
Cousins does not recognize the existence of state "protective"
laws.
g.
No difference is made between women and men as to retirement
age for any particular job.
h. Both women and men are eligible for all training programs and
benefits offered by Cousins. Cousins encourages women to
participate in management training programs both in-house and
outside Cousins.
3. Cousins has planned affirmative action (detailed elsewhere in this Plan)
to recruit women to apply for jobs where they may be or have been
underutilized.
4. Cousins makes no distinctions based on sex in training programs.
Access to training programs is not dependent on one's sex.
5. Cousins has a policy prohibiting sexual harassment in the work force.
6. Disabilities due to pregnancy are treated equal to or greater than any
other disability.
22
•
•
•
XII. COMPLIANCE WITH GUIDELINES ON DISCRIMINATION
BECAUSE OF RELIGION OR NATIONAL ORIGIN
[4f C.P.R. § 60-50]
1. Equal Employment Policy
[41 C.P.R. § 60-50.2(a-b)]
Cousins does the following to ensure that all applicants and employees
are not discriminated against because of religion or national origin:
a. Monitors employment practices to determine whether members of
various religious and/or ethnic groups are given equal job opportunities,
paying particular attention to executive and middle -management levels.
b. To ensure nondiscrimination based on religion or national origin,
Cousins is involved in the following outreach and recruitment activities,
as necessary:
(1)
Cousins communicates its obligation to provide equal
employment opportunity without regard to religion or national
origin to all employees, including executives, managers and
supervisors.
(2) Internal procedures exist at Cousins to implement equal
employment opportunity without regard to religion or national
origin.
(3)
Cousins periodically informs all employees of its commitment
to equal employment opportunity without regard to religion or
national origin.
(4) Recruitment sources are used to provide equal employment
opportunity without regard to religion or national origin.
(5)
Cousins reviews employment records to determine the
availability of promotable and transferable members of various
religious and ethnic groups.
23
•
•
Accommodations to Religious Observance and Practice
[41 C.F.R. § 50-50.3]
Cousins accommodates the religious observances and practices of
employees or prospective employees except where such accommodation causes
undue hardship on the conduct of Cousins' business. The extent of our
obligation is determined by considering business necessity, financial costs and
expenses and resulting personnel problems.
3. Nondiscrimination
[41 C.F.R. § 60-50.5]
In implementing its EEO policy regarding nondiscrimination because of
religion or national origin, Cousins does not discriminate against any qualified
employee or applicant for employment because of race, color, religion, sex, or
national origin.
24
•
•
•
XIII. SUPPORT OF COMMUNITY ACTION PROGRAMS
[41 C.F.R. §§ 60-2.13(i); 2.26(a-1)1
Pursuant to 41 C.F.R.. § 60-2.13(i), contractors are required to document their efforts to
actively support local and national community action programs designed to improve the
employment opportunities of minorities and women. Cousins has engaged in the following
activities:
1. Cousins supports members of management who serve on merit employment
councils, community relation boards, and similar organizations.
Cousins and its employees participate a variety of community support
programs and/or organizations.
3. Cousins personnel are available for lectures promoting women and minorities
in the industry.
4. In addition to our regular program of Corporate Giving, Cousins regularly
honors requests for donations in the form of contributions, advertising, and
services. Cousins and its employees plan, sponsor, and participate in numerous
community oriented activities and social programs.
25
•
•
•
XIV. ADDITIONAL CONSIDERATION OF MINORITIES AND
FEMALES NOT CURRENTLY IN THE WORKFORCE
[41 C.F.R. § 60-2. a 3W]
Cousins takes affirmative action to recruit minorities and women having requisite
skills not currently in the work force. Cousins will consider taking the following measures to
reach out to recruit said persons:
1. Part-time employment may be offered in some departments,
2. Flexible hours (flex -time) may be offered in some departments.
3. Cousins may engage in high school and college intern or Co-op
programs at educational institutions, as necessary and where
appropriate.
4. Cousins places help -wanted advertisements in newspapers, which are
likely to reach households in which there are minorities and females
who are not currently in the work force, and recruits over the Internet,
which reaches globally.
S. Cousins will recruit at schools, colleges and universities to attract
minorities and females who are not currently in the work force
whenever openings justify.
6. Cousins actively encourages employee involvement in community
programs which will assist persons interested in employment
opportunities.
26
•
•
•
XV. REPORT ON PRIOR YEAR GOALS
Cousins became obligated to develop this affirmative action plan by virtue of its status
as a covered federal subcontractor. Accordingly, there are no prior year goals on which to
report. Cousins has set goals, however, for the upcoming plan year. A report on these goals
will be included as part of next year's affirmative action plan.
27
•
•
•
XVI. CONCLUSION
The Affirmative Action Plan, 2000-2001 shows a continued commitment to equal
employment opportunity and affirmative action and strong plans to ensure both corporate and
employee success.
Through its Affirmative Action Officer, [Name], Cousins will continue to
communicate its policies, both within the organization and to the community in which we
work. The CEO affords the Affirmative Action Officer full authority to take action to
implement the Plan and to pursue solutions to problems which might impede the progress of
this Plan.
At the close of Cousins' most recent plan year, an analysis of the composition of the
work force was undertaken. The work force was analyzed by job group and by department to
determine the employment availability of minorities and females and to determine if any
underutilization exists when compared to the appropriate external work force. This analysis
revealed only limited areas of underutilization which are statistically significant, showing that
for the overwhelming majority of the work force, employment levels of females and
minorities are representative of our recruiting population. Nonetheless, Cousins has made
plans to achieve an even more positive affirmative action posture.
Cousins is mindful of the fact that continued achievements in the area of equal
employment opportunity and affirmative action are important. As a result, we have included
additional action oriented plans and programs for recruiting, communication and reporting to
ensure that our compliance with affirmative action continues in good stead.
Finally it should be noted that Cousins' thorough analysis of its work force reveals that
it is in full compliance with sexdiscrimination guidelines and that there is no evidence of
discrimination in any form against female employees. As outlined in this Affirmative Action
Plan, Cousins is ready and willing to make affirmative action both a commitment and a
continued reality.
2g
ATTORNEY CLIENT
PRIVILEGED
•
•
•
AFFIRMATIVE ACTION PLAN FOR VETERANS AND DISABLED VETERANS
COUSINS PROPERTIES
AFFIRMATIVE ACTION PLAN YEAR SEPTEMBER I, 2000 - AUGUST 31, 2001
Developed Pursuant to Section 503 Of T1)e Rehabilitation Act of 1973, .As A.tnended
And 41 C.F.R part 6(} 741 and Section 402 of the Vietnam Era Veterans Readlustnret'
Assistance of 1974_ and 41C3 ,R part:_60 250 F
I. PREFACE
Cousins Properties (also referred to as Cousins) is committed to the concept and practice of
equal opportunity and affirmative action. In the preparation of this Affirmative Action Plan, the
Rehabilitation Act of 1973 (as amended), specifically, 29 U.S.C. Section 793 and its implementing
OFCCP regulations (41 C.F.R. Part 60-741), or the Vietnam Era Veteran's Readjustment Assistance
Act of 1974, as amended (38 U.S.C. Sections 4211, et. seq.), or OFCCP's implementing regulations
(41 C.F.R. Chapter 60) have been used as a guide by Cousins. Therefore, the use of such terminology
should not be construed as an admission by Cousins, in whole or in part, that in fact that either disabled
persons or covered veterans have been or are presently being underutilized, concentrated, or
discriminated against in any way by the Plan in violation of federal, state or local fair employment
practice laws. Further, nothing contained in this Affirrnative Action Plan or its supporting data should
be construed as an admission by Cousins, in whole or in part, that it has contravened such federal, state
or local employment practice laws.
In developing and implementing this Affirmative Action Plan, Cousins has been guided by its
established policy of providing equal employment opportunity. Nothing herein is intended to sanction
the discriminatory treatment of any person. Thus, this Affirmative Action Plan has been developed in
strict reliance upon the Guidelines on Affirmative Action issued by the Equal Employment Opportunity
Commission (EEOC) (29 C.F.R. Part 1608).
While Cousins firmly believes in wide dissemination of its affirmative action policies and equal
employment opportunity practices, there is certain proprietary information relating to its business
which must be kept confidential. The detailed information provided in good faith as a part of the
Affirmative Action Plan contains specific information which, if disseminated, can be detrimental to the
competitive and business interest of this Cousins. At a minimum, the complexity of this data is subject
to misinterpretation and misuse which again can be very harmful to business goals and objectives,
solely unrelated to the affirmative action and equal employment opportunity concept. Therefore, even
though Cousins is justifiably proud of the progress and goals that are described in the following pages,
the following is requested:
1. If this information is submitted to the Office of Federal Contract Compliance Programs
(OFCCP) pursuant to the relevant Executive Order and regulations, it is to be
considered confidential and not subject to disclosure without notifying Cousins of the
agency's decision to disclose and providing Cousins with ample time to contest the
disclosure.
2. If this information is supplied to a government contractor, EEOC representative, or any
other person who is given access to the Affirmative Action Plan, it is not to be copied,
reproduced, or disclosed without prior notification to Cousins.
30
•
•
3. No information contained in the Affirmative Action Plan is to be copied, removed from
the premises, or released to other individuals without a prior notification to Cousins.
4. All monitoring system reports as required by federal regulations and laws have been
completed. Reports which require specific data such as names of employees and salary
information have not been included within the context of this Plan. This information is
on file at Cousins as Documentation and Supporting Data for Affirmative Action Plan
Reports and is available for review only as required by law.
The material set forth in this Affirmative Action Plan is the property of Cousins and is deemed
to constitute trade secrets, operations information, confidential statistical data and other confidential
commercial and financial data, within the meaning of the Freedom of Information Act, 5 U.S.C.
Section 552, Title VII of the Civil Rights Act of 1964 (as amended), 42 U.S.C. Sections 2000e et seq.,
the Trade Secrets Act, 18 U.S.C. Section 1905, and 44 U.S.C. Section 3508, the disclosure of which is
prohibited by law and would subject the individual making the disclosure to criminal and/or civil
sanctions.
This Affirmative Action Plan does not constitute an express or implied contract between
Cousins and its employees, job applicants, or other persons, nor does it change in any way the basic at -
will employment relationship which all Cousins employees have with Cousins.
31
•
•
•
II. AFFIRMATIVE ACTION PLAN STATEMENT OF POLICY
It is the policy of Cousins not to discriminate on the basis of a physical or mental disability or
an individual's status as a disabled veteran or veteran of the Vietnam Era with regard to recruitment or
recruitment advertising, hiring, training, promotion, and other terms and conditions of employment,
provided the individual is qualified, with or without reasonable accommodations, to perform the
essential functions of the job. Cousins does and will take affirruative action to employ, advance in
employment, and otherwise treat qualified individuals with disabilities, qualified disabled veterans,
qualified veterans of the Vietnam Era, and other covered veterans without discrimination based upon
their physical or mental disability, or veterans' status in all employment practices as follows:
All personnel actions or programs that affect qualified individuals with disabilities, disabled
veterans, and veterans of the Vietnam Era, such as employment, upgrading, demotion or transfer,
recruitment, advertising, termination, rate of pay or other forms of compensation, and selection for
training will be made without discrimination based upon the individual's physical or mental disability
or veterans' status.
Cousins makes and will continue to make reasonable accommodations to promote the
employment of qualified individuals with disabilities and disabled veterans unless such
accommodations would impose an undue hardship on Cousins' business.
Becky Garrigan, Affirmative Action Officer, will manage Cousins' Affirmative Action Plan for
individuals with disabilities, disabled veterans, veterans of the Vietnam Era, and other covered
veterans. All managers and supervisors will take an active part in Cousins' Affirmative Action Plan to
ensure that all qualified employees with disabilities, disabled veterans, veterans of the Vietnam Era,
and other covered veterans and prospective employees are considered and treated in a non-
discriminatory manner with respect to all employment decisions. Furthermore, Cousins will solicit the
cooperation and support of all employees for Cousins' policy and Affirmative Action Plan. The
Affirmative Action Officer has been assigned responsibility for periodically reviewing progress in the
compliance and implementation of the policy of affirmative action for individuals with disabilities,
disabled veterans, veterans of the Vietnam Era, and other covered veterans. In accordance with public
law, Cousins' program of afflnnative action for individuals with disabilities, disabled veterans,
veterans of the Vietnam Era, and other covered veterans is available for inspection in the Human
Resources Department during regular business hours upon request.
In addition, as required by the Rehabilitation Act of 1973, as amended, employees and
applicants shall not be subjected to harassment, intimidation, threats, coercion or discrimination
because they have engaged in or may have engaged in activities such as filing a complaint, assisting or
participating in an investigation, compliance review or hearing, or opposing any act or practice made
unlawful, or exercising any other right protected by the Act.
T. G. Cousins
Chairman and CEO
Cousins Properties
Effective September 1, 2000
32
•
•
•
III. DEFINITIONS
A. "DISABLED VETERAN" means a person entitled to disability compensation under
laws administered by the Veterans Administration for disability rated at 30 percent or
more, or a person whose discharge or release from active duty was for a disability
incurred or aggravated in the line of duty.
B. "QUALIFIED DISABLED VETERAN" means a disabled veteran as defined above who
is capable of performing the essential functions of a particular job when reasonable
accommodations are made to his or her disability.
C. "VETERAN OF THE VIETNAM ERA" means a person who (i) 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 therefrom with other than a
dishonorable discharge, or (ii) was discharged or released from active duty for a service -
connected disability if any part of such active duty was performed between August 5,
1964 and May 7, 1975.
D. "INDIVIDUAL WITH A DISABILITY" means a person who, generally, (i) has a
physical or mental impairment that substantially limits one or more of his or her major
life activities, (ii) has a record of such impairment, or (iii) is regarded as having such
impairment.
For the purpose of this Plan, an individual with a disability is "substantially limited" if
he or she is unable to perform a major life activity that the average person in the general
population can perform, or is significantly restricted as to the condition, manner or
duration under which a person can perform a particular major life activity as compared
to the condition, manner or duration under which the average person could perform that
same activity.
E. "A QUALIFIED INDIVIDUAL WITH A DISABILITY" means an individual with a
disability as defined above who, meets the job related requirements of a particular job
and is capable of performing that job, with or without reasonable accommodation for his
or her disability.
F "OTHER COVERED VETERAN" means a veteran who served on active duty during a
war or in a campaign or expedition for which a campaign badge has been authorized.
This includes individuals who are veterans of World War II (i.e. who had active duty
33
•
•
•
service between December 7, 1941 and April 28, 1952) or who served during one of the
campaigns or expeditions identified on the attached list.
34
•
•
•
IV. RESPONSIBILITY FOR AFFIRMATIVE ACTION
Affirmative action for individuals with disabilities and covered veterans (Vietnam Era and
disabled) is the responsibility of every employee at Cousins. [Name], Cousins' Affirmative Action
Officer is responsible for the implementation and monitoring of this Affirmative Action Plan at
Cousins. [Name] has the support and staff to manage the implementation of this Plan. In carrying out
this responsibility, the Affirmative Action Officer and designated staff will undertake efforts that may
include:
Develop policy statements, affirmative action programs, and internal and external
modes of communication;
Oversee regular discussions with local managers, supervisors, and employees to ensure
that Cousins' policies are being followed;
Identify, in conjunction with line management, known disabled employees, disabled
veterans, veterans of the Vietnam Era, and any problem areas in implementing the
Affirmative Action Plan, and develop solutions, including possible modes of
accommodation;
Work with attorneys to design and implement internal audit and reporting systems that
will measure the effectiveness of Cousins' Plan, indicate the need for remedial action,
determine the degree to which Cousins' objectives have been attained, determine
whether known employees with disabilities and covered veterans have had the
opportunity to participate in all Cousins sponsored educational, training, recreational
and social activities, and ensure that each Cousins location is in compliance with the act
and federal regulations listed;
Serve as liaison between Cousins and enforcement agencies, and between Cousins and
organizations of and for persons with disabilities and covered veterans, and encourage
active involvement by Cousins representatives in the community service programs of
local organizations of and for individuals with disabilities and covered veterans;
Keep management informed of the latest developments in the entire affirmative action
area;
Provide career counseling for known disabled and covered veteran employees, where
appropriate.
35
•
•
V. IMPLEMENTATION OF AFFIRMATIVE ACTION INVITATION TO INDIVIDUALS
WITH DISABILITIES, VIETNAM ERA VETERAN AND DISABLED VETERAN
APPLICANTS AND EMPLOYEES
Cousins will invite employees and job applicants who are individuals with disabilities, disabled
veterans, or veterans of the Vietnam Era and believe themselves covered by the Rehabilitation Act of
1973 or the Vietnam Era Veterans Readjustment Assistance Act of 1974 to identify themselves in order
to receive the benefits of affirmative action. When job applicants or current employees identify
themselves pursuant to the invitation, Cousins will seek their advice regarding proper placement and
proper accommodation in view of their disability, or veteran status.
VI. REVIEW OF PERSONNEL PROCESSES
Cousins continues to review its personnel procedures to determine whether they assure the
careful, thorough, and systematic consideration of the job qualifications of employees or job applicants
who are known individuals with disabilities, disabled veterans, or veterans of the Vietnam Era for job
vacancies, promotions, and/or educational or training opportunities and to assure that they are so
designed as to facilitate the implementation of Cousins' affirmative action obligations.
Vacancies are advertised, and applications are accepted from any interested person. Cousins'
employment application includes the statement that Cousins is an Equal Opportunity Employer to
further assure applicants of Cousins' policy of equal employment. All positions which are not
expected to be filled from within will be referred to the State Department of Employment and Training
or America's Job Bank, as well as other recruiting sources.
The disability or veteran status of any otherwise qualified individual who applies for any
vacancy, promotion, transfer, or training opportunity will not be a factor in these employment decisions
since the physical and mental job qualifications reviewed ensure that they do not tend to screen out
individuals with disabilities, disabled veterans, or veterans of the Vietnam Era for reasons that are
neither job -related, consistent with business necessity, nor consistent with the safe performance of the
essential functions of the job. Thus, individuals with disabilities, disabled veterans, and veterans of the
Vietnam Era who meet these qualifications will be considered on an equal basis with all other
applicants. Moreover, military experience is considered by Cousins only to the extent that it increases
the veteran's qualification for the job.
Consistent with the regulations, Cousins has instituted the following procedures to further
assure the careful, thorough, and systematic consideration of the job qualifications of employees or job
applicants who are known individuals with disabilities, disabled veterans, or veterans of the Vietnam
36
•
Era for job vacancies, promotions, and/or educational or training opportunities and to assure that they
are so designed as to facilitate the implementation of Cousins' affirmative action obligations:
As covered individuals apply for positions within Cousins, their personnel forth
will be annotated to identify each vacancy for which he or she was considered.
2. Where applicants or employees are selected for hire, promotion or training and
Cousins undertakes any accommodation which makes it possible to place a
covered individual on the job, the personnel file will contain a description of that
accommodation.
VII. REVIEW OF PHYSICAL AND MENTAL JOB QUALIFICATIONS
Cousins has recently reviewed physical or mental job qualification requirements to ensure that
qualification requirements do not screen out qualified individuals with disabilities, disabled veterans,
and veterans of the Vietnam Era for reasons that are not job related, consistent with business necessity
and the safe performance of the essential functions of the job.
. VIII. ACCOMMODATIONS
•
Cousins has made and intends to continue to make reasonable accommodations, which do not
impose undue hardships on its business, to the physical and mental limitations of employees and job
applicants.
Some specific accommodations for disabled and covered veteran employees that have been
implemented may include the following:
1. A personal leave policy which enables eligible employees to accumulate paid
time off to be used for medical appointments, personal illness, or any other
reason.
2. A medical Ieave of absence policy exists for all eligible employees.
3. Should reasonable accommodations be necessary to facilitate access to work
areas by qualified employees with disabilities, Cousins will take any reasonable
steps to provide such accommodations.
4. When possible, Cousins will redesign jobs to meet the needs of employees with
disabilities.
37
•
5. Cousins will arrange suitable work hours for employees returning from sick
leave, leave of absence, and long term disability where that arrangement is
possible.
6. Cousins will accommodate employees with disabilities by allowing a reasonable
amount of time off for physicians visits_
7. Special parking for individuals with disabilities is available at Cousins.
IX. COMPENSATION
In offering employment or promotions, Cousins does not reduce the amount of compensation
offered to individuals with disabilities, disabled veterans, or veterans of the Vietnam Era because of
any disability income, pension, or other benefit that the employee receives from another source.
X. OUTREACH, POSITIVE RECRUITMENT AND EXTERNAL
DISSEMINATION OF POLICY
Cousins has reviewed its employment practices to determine whether personnel programs
provide the required affirmative action for employment and advancement of qualified individuals with
disabilities, disabled veterans, and veterans of the Vietnam Era.
While Cousins believes that there are no deficiencies in its current employment practices with
respect to these employees, it has planned the following outreach, positive recruitment and external
dissemination programs, however, to augment its existing affirmative efforts:
A. External:
1. Cousins will communicate to employees its obligation to take affirmative action
to employ qualified individuals with disabilities, disabled veterans, and veterans
of the Vietnam Era and will encourage employee referrals of covered applicants.
?.
All executives, management officials, supervisors involved in the recruiting and
selection process of Cousins will be encouraged to assist in the effort to
disseminate Cousins' policy of affirmative action to individuals outside Cousins.
3. Cousins will inform recruiting sources of Cousins' equal employment policy that
includes individuals with disabilities, disabled veterans, and veterans of the
38
•
•
Vietnam Era. Recruiting sources will be requested to actively recruit and refer
qualified individuals with disabilities, disabled veterans, and veterans of the
Vietnam Era for all positions.
4. Cousins will enlist the assistance and support of local recruiting sources, social
service agencies, and organizations especially knowledgeable about the
availability of disabled individuals and veterans of the Vietnam Era.
5. Cousins will incorporate the affirmative action for individuals with disabilities
clause in purchase orders and contracts that are made by Cousins and are
covered by the Rehabilitation Act of 1973 and its implementing regulations.
The affirmative action clause for disabled veterans and Vietnam Era veterans
will be incorporated in purchase orders and contracts made by Cousins that are
covered by the Vietnam Era Veterans Readjustment Act of 1974 and its
implementing regulations.
6. Where possible, Cousins will snake reasonable accommodations for disabled
individuals and disabled veterans.
7. Cousins will take positive steps to attract qualified individuals with disabilities
and covered veterans not currently in the work force who have requisite skills
and can be recruited through affirmative action measures.
Cousins will review the employment records of its known employees with
disabilities, disabled veterans, and veterans of the Vietnam Era to determine the
availability of promotable, qualified, individuals with disabilities, and to
determine whether present and potential skills are being fully utilized or
developed.
9. Cousins will send written notification of Cousins policy to all contractors,
subcontractors, vendors, and suppliers retained in conjunction with Cousins'
work as a covered federal subcontractor requesting appropriate action on their
part.
10, When Cousins advertises in newspapers for prospective employees, the
advertisement will include the EEO solicitation: "Equal Opportunity Employer"
or a relevant abbreviation.
XI. INTERNAL DISSEMINATION OF POLICY
39
•
•
Cousins recognizes that however strong its outreach program, internal support from supervisory
management and other employees is necessary to ensure maximum effectiveness of its plan of
affirmative action for individuals with disabilities, disabled veterans, and veterans of the Vietnam Era,
so that these employees' awareness of the needs of individuals with disabilities can be increased.
Accordingly, Cousins may utilize the following procedures to maximize the internal implementation
and dissemination of its policy, as necessary or appropriate:
1. All employees are given the opportunity to identify themselves as disabled veterans, its
veterans of the Vietnam Era.
2. Cousins' policy on affirmative action for veterans and individuals with disabilities is
posted on Cousins bulletin boards. The posting includes a statement that employees and
applicants are protected from coercion, intimidation, and interference or discrimination
for filing a complaint or assisting in an investigation under the Rehabilitation Act or the
Vietnam Era Veterans Readjustment Act.
3. An invitation to participate in Cousins' policy of affirmative action has been included
with the application for employment.
4. Since Cousins has no direct collective bargaining agreement, no notification of union
officials is necessary.
XII. DEVELOPMENT AND EXECUTION OF AFFIRMATIVE ACTION
PROGRAMS
In addition to the affirmative action programs mentioned supra, Cousins may undertake the
development and execution of the following programs:
1. Cousins will continue to review all physical or mental job qualifications.
2,
Cousins will continue to review and evaluate its entire personnel selection process,
including training and promotion, to ascertain whether the process permits the
stereotyping of individuals with disabilities, disabled veterans, and veterans of the
Vietnam Era in a manner that limits their access to jobs for which they are qualified.
3. All personnel involved in the recruitment, screening, selection, promotion, disciplinary,
and related processes will be subjected to training materials on affirmative action for
individuals with disabilities, disabled veterans, and veterans of the Vietnam Era.
40
•
•
•
4. As Cousins makes employees available for participation in community activities,
employees with disabilities, disabled veterans, or veterans of the Vietnam Era will be
among those who are encouraged to participate.
XHI. INTERNAL REVIEW PROCEDURE
Cousins is developing an internal review procedure whereby individuals with disabilities and
covered veteran employees can raise any issues or claims that may arise during the course of and
concerning their employment. General communications procedures encourage any and all employees
including those with a disability, disabled veterans, and veterans of the Vietnam Era to discuss such
issues or claims. All matters brought to the attention of the Affirmative Action Officer will be
formally and confidentially addressed.
XIV. MONITORING AND REPORTING SYSTEMS
It is the responsibility of Cousins' Affirmative Action Officer to monitor all employment and
personnel practices to ensure compliance with applicable regulations and adherence to Cousins'
Statement of Policy, to report specific problems to the appropriate management personnel, and to
measure the effectiveness of Cousins' Affirmative Action Plan.
In this regard all records concerning disabled and covered veteran applicants will be maintained
for two years, and all personnel actions involving these employees will be individually maintained as a
part of their personnel files.
Special reports summarizing affirmative action efforts to assist covered employees, descriptions
of any formal complaints, etc. will he provided to upper management personnel at least annually. This
Affirmative Action Plan will be updated annually and will include a summary of the previous year's
actions and programs.
A copy of Cousins' Disabled and Veteran Summary is attached to this plan. The summary
reflects Cousins' commitment to ensuring equal employment opportunity for disabled individuals and
covered veterans, for which Cousins is justifiably proud.
41
•
CAMPAIGN/EXPEDITION DATES ORGANIZATIONS PARTICIPATING
START
END ARMY NAVY AIR MARINE COAST
FORCE CORP GUARD
Carnpairtn or Service Medals
American Defense Service 09/08/39 12/07/41 X X -- X X
Army Occupation of Austria 05/09/45 07/27/55 X _ X — -"
Army Occupation of Berlin 05/09/45 10/02/90 X X X X X
Army Occupation of Germany 05/09/45 05/05/55 X X X -- X
Army Occupation of Japan 09/03/45 04/27/52 X X X X X
China Service 07/07/37 09/07/39 X - X --
China Service Medal (Extended) 09/02/45 04/01/57 — X -- --
Korean Service 06/27/50 07/27/54 X X X X X
Navy Occupation of Trieste 05/09/45 10/25/54 X -- X X
Navy Occupation of Austria 05/08/45 10/25/55 X `-
Navy Occupation of Berlin 05/08/45 10/02/90 X X
Navy Units of the Sixth Fleet 05/09/45 10/25/55 -- X
SW Asia Service Medal 08/02/90 11/02/95 X X X X X
(Desert Shield/Storm)
Vietnam Service Medal (VSM) 07/04/65 03/28/73 X X X X X
Armed Farces Expeditionary Medal
(_AFEM)
Berlin 08/14/61 06/01/63 X X X X X
Bosnia and Herzegovina 11/20/95 12/20/96 X X X X X
(Joint Endeavor)
Bosnia and Hercegovina (Joint Guard) 12/20/96 Present X X X X X
Cambodia 63/29/73 08/15/73 X X X X X
Cambodia Evacuation (Eagle Pull) 04/11/75 04/13/75 X X X X X
Congo 67/14/60 09/01/62 X X X X X
Congo I1/23164 11/27/64 X X X X X
Cuba 10/24/62 06/01/63 X X X X X
Dominican Republic 04/28/65 09/21/66 X X X X X
El Salvador 01/01/81 02/01/92 X X X X X
Grenada (urgent Fury) 10l23/83 11/21f83 X X X X X X X
Haiti (uphold Democracy) 09/16/94 03/31/95 X X X
Iraq (Northern Watch) 01/01/97 Present X X X X X
Korea 10/01/66 06/30/74 X X X X X
Laos 04/19/61 10/07/62 X X X X X
Lebanon 07/01/58 11/0I/58 X X X X X
Lebanon 06/01/83 12/0I/87 X X X X X
Libyan Area (Eldorado Canyon) 04/12/86 04/17/86 X X X X X
Mayaguez Operation 05/15/75 05/15/75 X X X X X
Panama (.lust Cause) 12/20/89 01/31/90 X X X X X
Persian Gulf (Earnest Will) 07/24/87 08/01/90 X X X X X
Persian Gulf 08/02/90 01/02/92 X X X X X
Persian Gulf (Southern Watch) 12/01/95 Present X X X X X
Persian Gulf (Vigilant Sentinel) 12/01/95 02/15/97 X X X X X
Persian Gulf Interception 12/01/95 Present X X X X X
Operation
Quemoy and Matsu Islands 08/23/58 06/01/63 X X X X X
Somalia (Restore hope) 12/05/92 03/31/95 X X X X X
Taiwan Straits 08/23/58 01/01/59 X X X X X
Thailand 05/I6/62 08/10/62 X X X X X
Vietnam and Thailand 07/01/58 07/03/65 X X X X X
Vietnam Evacuation 04/29/75 04/30/75 X X X X X
Navy Expeditionary Medal and Marine
Corp Expeditionary Medal
Cuba 01/03/61 10/23/62 X
Indian Ocean/Iran 11/21/79 10/20/81 — X
Iranian/Yemen/Indian Ocean 12/08/78 06/06/79 -• X
Lebanon 08/20/82 05/31/83 — X
Liberia (Sharp Edge) 08/05/90 02/21/91 — X
Libyan Area 01/20/86 06/27/86 X
Panama 04/01/80 12/19/86 X
Panama 02/01/90 06/13/90 X
Persian Gulf 02/01/87 07/23/87 X
Rwanda (Distant Runner) 04/07/94 04/18/94 X
XX XXXXXXX
42