Nondiscrimination Policy & Grievance Procedure

This notice applies to applicants, employees, program job-seekers, trainees, applicants for admission to any Center for Workforce Inclusion (Center) programs or activity supported by Center employees, applicants for employment, (including visitors, contractors, and other members of the public, which may include those seeking to participate in or otherwise participating in grant programs or activities of the Center).

The Center for Workforce Inclusion (Center) does not discriminate on the basis of race, color, national origin, disability, age, sex, or any other characteristic protected by federal law, in administration of its programs or activities, as required by applicable laws and regulations. Center does not intimidate or retaliate against any individual or group because they have exercised their rights to participate in actions protected, or oppose action prohibited, by 40 C.F.R. Parts 5 and 7, or for the purpose of interfering with such rights.

Margaret Daniels, CHRO, is responsible for coordination of compliance efforts and receipt of inquiries concerning non-discrimination requirements implemented by 40 C.F.R. Parts 5 and 7 (Non-discrimination in Programs or Activities Receiving Federal Assistance from the Environmental Protection Agency), including Title VI of the Civil Rights Act of 1964, as amended; Section 504 of the Rehabilitation Act of 1973; the Age Discrimination Act of 1975; Title IX of the Education Amendments of 1972; and Section 13 of the Federal Water Pollution Control Act Amendments of 1972 (hereinafter referred to collectively as the federal non-discrimination laws).

If you have any questions about this notice or any of the Center for Workforce Inclusion’s non-discrimination programs, policies or procedures, you may contact:

Margaret Daniels, CHRO

• Address: Center for Workforce Inclusion, Inc., 8403 Colesville Road, Suite 200, Silver Spring, MD 20910-6391
• Email: mdaniels@workforceinclusion.org
• Phone: 301-578-8836
• fax number: 301-578-8879

This Notice and Policy statement prohibits the following conduct which includes, but is not limited to (“Prohibited Conduct”):

1. Harassment or discrimination, including, but not limited to, Sex-Based Misconduct against job-seekers, enrollees, trainees, employees and members of the public based on a protected category;
2. Harassment or discrimination based on the perception that a person is a member of a protected category or is associated with a person who has, or is perceived to have, membership in a protected category;
3. Any and all retaliation against any person for submitting a report of violation of this policy or for cooperating in the administration of this policy, including participation in an investigation or adjudication process;
4. Knowingly submitting a complaint under this policy based on false allegations or to knowingly provide false information in connection with an investigation or adjudication of a complaint processed under this policy;
5. Any responsible employee who fails to report allegations of Prohibited Conduct, including, but not limited to, Sex-Based Misconduct or Title IX Sexual Harassment;
6. Any person in a position of power or influence that intentionally deters or hinders another person from reporting allegations of conduct which, if true, would violate this Policy statement;
7. Any other violation of this Policy.

Any employee, jobseeker, trainee or member of the public has the right to raise concerns or make a complaint regarding discrimination or harassment under this policy without fear of retaliation and/or intimidation. It is a violation of the Center’s policies to retaliate against an individual for filing a complaint of discrimination or harassment or for cooperating in an investigation of alleged discrimination or harassment. Any person at the Center found in violation of this policy is subject to disciplinary action up to and including termination of employment or expulsion from the Center programs. If you have any questions or concerns, please contact Ms. Margaret Daniels, the Center’s Non-Discrimination Coordinator, at the contact information below.

Title VI of the Civil Rights Act of 1964 prohibits recipients of Federal financial assistance from discriminating against or otherwise excluding individuals on the basis of race, color, or national origin in any of their activities. Section 601 of Title VI, 42 U.S.C. § 2000d, provides “No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.” The Center takes reasonable steps to ensure “meaningful” access to the program, activity, information and services we provide to eligible persons with limited English proficiency (LEP).

To the extent required by law, the Center provides for and maintains a system to collect demographic data to determine how effectively the Center programs are reaching potential eligible persons and beneficiaries, and to help us identify areas where additional outreach is needed, assist in the selection of locations for compliance reviews, and complete reports as required by applicable law and regulations.

The Center may require all program applicants and participants to identify all the racial categories that apply consistent with current federal guidance. Respect for individual dignity guides Center’s processes and methods for collecting data on race and ethnicity. Self-identification and self-reporting will be facilitated to the greatest extent possible. The Center may request and collect this information solely for the purpose of determining compliance with applicable civil rights laws, and responses will not affect consideration of an applicant’s or participant’s application and may be protected by the Privacy Act. By providing this information, applicants and participants will assist the Center in assuring that its programs are administered in a nondiscriminatory manner.

If an applicant or participant declines to self-identify, to the extent possible and practicable, a visual identification of the applicant’s or participant’s race and ethnicity will be made and recorded in the Center’s data system, and the Center will have the opportunity to verify the information recorded.

Any data collected under this section will be maintained for a minimum of three (3) years, and in accordance with the Center’s records retention schedules.  The data will also be maintained under safeguards that restrict access of records only to authorized personnel.

This policy statement shall be reviewed on an annual basis to determine if modifications are appropriate.

Legal Authority includes:

• Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d to 2000d-6
• Americans with Disabilities Act (28 CFR Part 35, Title II, Subtitle A)
• Title IX of the Education Amendments of 1972 (20 U.S.C. § 1681 et. seq.)
• Section 504 of the Rehabilitation Act of 1973
• Age Discrimination Act of 1975 (45 CFR Part 91)
• The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA)

This information may be made available in languages other than English.  Persons with disabilities who require alternative means of communication to obtain program information (e.g., Braille, large print, audiotape, American Sign Language), should contact teh Center’s Non-Discrimination Coordinator, Margaret Daniels.  Individuals who are deaf, hard of hearing or have speech disabilities may contact Margaret Daniels for additional information.

To begin the formal complaint process, the complainant or report, a Complainant should complete a Center Complaint Form which can be downloaded here:

Grievance Submittal Form in PDF

Grievance Submittal Form in Word

The Center Complaint Form can also be accessed by calling 301-578-8836, or by submitting a written letter by mail, fax or to the complaint email box below, addressed to the Center’s Nondiscrimination Coordinator, Margaret Daniels  The letter must contain the complainant’s name, address, telephone number, and a written description of the alleged discriminatory action in sufficient detail, and including any witnesses, to inform the Center about the nature and date of an alleged violation of this policy. Grievance must be submitted to the Center’s Non-Discrimination Coordinator within 90 days of the date of the person filing the grievance becomes aware of the alleged discriminatory action. The Center will take all available steps to address complaints of discrimination.

The Center will always respond to complaints, reports, allegations and information about discrimination that it knows or should know about, in order to stop prohibited conduct, prevent its recurrence and address any lingering effects from such conduct.

The Non-Discrimination Coordinator will acknowledge receipt of the grievance within 5 days and shall conduct an investigation of the complaint.  This investigation may be informal, but it will be thorough, affording all interested persons an opportunity to submit evidence relevant to the complaint.

The Non-Discrimination Coordinator will issue a written decision on the grievance, based on a preponderance of the evidence, no later than 30 days after its filing, including a notice to the complainant of their right to pursue further administrative or legal remedies. The written decision will include whether discrimination is found and the description of the investigation process.

The person filing the grievance may appeal the decision of the Center’s Non-Discrimination Coordinator by writing to the CFO/COO within 15 days of receiving the Non-Discrimination Coordinator decision. The CFO/COO will issue a written decision in response to the appeal no later than 60 days after its filing.

The Center recognizes the importance of privacy and confidentiality in these matters and will uphold the privacy and confidentiality of all parties to the extent practicable and allowable by applicable law.

Margaret Daniels, CHRO

• Address: Center for Workforce Inclusion, Inc., 8403 Colesville Road, Suite 200, Silver Spring, MD 20910-6391
• Email: mdaniels@workforceinclusion.org
• Phone: 301-578-8836
• fax number: 301-578-8879