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Non-Discrimination Policy

Astor Services for Children and Families (the “Agency”) affirms that it does not discriminate on the basis of sex, race, color, creed, religion, ethnicity, national origin, age, marital status, disability, sexual orientation, predisposition to genetic characteristics, military status, domestic violence victim status or any other legally protected category in the educational programs or activities which it operates.

Complainant Communications of Discrimination

Any employee who believes that he/she has been the victim of discrimination should communicate the alleged misconduct to the Agency’s EEO Compliance Officer as soon as possible after the incident in order to enable the Agency to effectively investigate and resolve the complaint. In the event the EEO Compliance Officer is responsible for the discrimination the employee should report the misconduct to the Executive Director. In the event the Executive Director is responsible for the discrimination the employee should report the misconduct to the President of the Board of Directors. The Agency will ensure that an investigation is commenced by appropriate individuals. The time limits set should be kept to the extent practicable.

The Victim is encouraged to submit the complaint in writing as set forth in Non-Discrimination Grievance Procedure; however complaints may be filed verbally. In order to assist the investigation, victims should document the discrimination as soon as it occurs and with as much detail as possible including: the nature of the discriminatory behavior, dates, times, places, name of person responsible for the conduct, witnesses, and victim’s response to the discriminatory behavior.

Non-Complainant Communications of Discrimination

  1. Employees may communicate to the Agency’s EEO Compliance Officer an observed incident(s) of discrimination. The Agency’s EEO Compliance Officer should keep a log of all of these communications and the action taken, if any.
  2. Employees who witness incidents of discrimination by employees or third parties against an employee or patron should promptly call that conduct to the attention of the individual responsible for the discrimination and report the same to the Agency’s EEO Compliance Officer.

Employee Recipients of Communications of Alleged Discrimination

Employees who are the recipients of employee communications alleging discrimination by an employee of the Agency are requested to encourage those complaining to promptly make their complaints to the EEO Compliance Officer.

Confidentiality

All complaints of discrimination will be kept as private as is reasonable to provide for the implementation of this Policy.

Discipline

The Agency considers discrimination to be a serious offense. Those employees who violate this Policy should expect serious consequences. The Agency condemns any retaliatory behavior against complainants, or potential complainants, reporters, communicators or witnesses, or anyone administering the Policy.
Employees whose conduct constitutes discriminatory or retaliatory behavior may be subject to disciplinary action, including reprimand, suspension or discharge from employment, even for a first time offense, if egregious, consistent with applicable federal and state laws.

Investigation of Complaints

Upon receipt of a complaint, the EEO Compliance Officer, or his/her designee, will conduct a thorough investigation of the charges. All reports are to be fully investigated even if the complainant does not wish to have that done. All investigations are to be completed within the timeframe set forth in the Non-Discrimination Grievance Procedure and kept as confidential to the extent practicable.

Both the complainant and the accused are entitled to fair treatment in the handling of the complaint, as well as to privacy and discretion to the extent practicable. In all of the proceedings described below, the complainant and the accused are each free to designate one other employee to accompany him or her to provide advice and moral support.

Alternate Responses to Proscribed Behavior

The procedure and provision of these Regulations shall not limit the Agency or its agents from other actions consistent with the law.

Publication of Policy

Copies of this Policy are to be distributed to all employees including the EEO Compliance Officer and Executive Director and posted in appropriate places.

Definitions

“Employee” shall mean all administrative, support personnel and volunteers.

“Complainant” shall mean an employee who complains of being the object of discrimination. “Complaint” shall mean a statement concerning discrimination made by Complainant.

“Reporter” shall mean any employee or other individual who informs the EEO Compliance Officer, the Director, or his/her designee, or the President of the Board of Directors of an incident(s) of discrimination which has been observed by that individual or which has come to the individual’s attention.

“Report” shall mean a statement about discrimination made by a reporter.

Employee Complaints to Agencies

The Agency acknowledges that while it would like employees to raise issues of discrimination pursuant to this Policy so that they can be addressed by it, any employee has the legal right to immediately make a complaint to the appropriate governmental entity:

Equal Employment Opportunity Commission (EEOC) at the New York District Office, 33 Whitehall Street, 5th Floor, New York, New York 10004; or to the New York State Division of Human Rights at 8 John Walsh Blvd. Suite 204 Peekskill, New York 10566

Please take notice that the failure to file a complaint with these agencies within the statutory period may result in the loss of your legal rights

Annual Notification

At the beginning of each year, the Agency shall publish this notice and grievance procedure for resolving complaints of discrimination due to an employee’s membership in a protected category. The notice and grievance procedure shall, among other things:

  1. inform employees that education programs are offered without regard to one’s sex, race, color, creed, religion, ethnicity, national origin, age, marital status, disability, sexual orientation, predisposition to genetic characteristics, military status, domestic violence victim status or any other legally protected category; and
  2. provide the name, address and telephone number of the person designated to coordinate activities concerning alleged discrimination.

Civil Rights Act of 1964, as amended in 1972,
Title VI [42 USC §§2000d et. seq.], Title VII [42 USC §§2000e et. seq.]
Section 504 of the Rehabilitation Act of 1973 and the Americans With Disabilities Act of 1990, 42 USC §§12101 et seq.
Education Amendments of 1972, Title IX (P.L. 92-318)
Age Discrimination in Employment Act
Executive Law §§290 et seq.
45 Code of Federal Regulations (CFR), Part 90 (Federal Register, June 4, 1975, August 11, 1975)