Non-discrimination Policies and Complaint Procedures

The Water Research Foundation (WRF) will make reasonable accommodation for qualified individuals with known disabilities unless doing so would results in an undue hardship to WRF or cause a direct threat to health or safety. WRF will make reasonable accommodations for employees whose work requirements interfere with a religious belief unless doing so would result in an undue hardship to WRF. Employees needing such accommodation, are instructed to contact their manager or Human Resources.

The Water Research Foundation (WRF) is dedicated to the principles of equal employment opportunity (EEO). We prohibit unlawful discrimination and harassment against applicants or employees based on an individual’s age being 40 and over, race (including traits historically associated with race, such as hair texture and length, protective hairstyles), sex, sexual orientation, gender identity, gender expression, color, religion, national origin, disability, military status, genetic information, veteran status, or any other status protected by applicable state or local law.

This prohibition includes unlawful harassment based on any of these protected classes. Unlawful harassment includes verbal or physical conduct which has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment. This policy applies to all employees, including managers, supervisors, co workers, and non-employees such as customers, clients, vendors, consultants, etc.

WRF strives to maintain a work environment free of unlawful harassment. Unlawful harassment includes verbal or physical conduct or any written, pictorial, or visual communication directed at an individual (or group) because of that individual's (or group's) membership in, or perceived membership in, a protected class that is subjectively offensive to the individual alleging harassment, and is objectively offensive to a reasonable individual who is a member of the same protected class. Harassment does not need to be in-person and can occur over electronic media such as Zoom or other electronic platforms. Prohibited behavior may include but is not limited to the following:

• Written form such as cartoons, e-mails, posters, drawings, or photographs.
• Verbal conduct such as epithets, derogatory comments, slurs, or jokes.
• Physical conduct such as assault or blocking an individual’s movements.
   

This policy applies to all employees including managers, co-workers, and non-employees such as customers, clients, vendors, consultants, etc.

Because sexual harassment raises issues that are to some extent unique in comparison to other types of harassment, WRF believes it warrants separate emphasis.WRF strongly opposes sexual harassment and inappropriate sexual conduct. Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature, when:

• Submission to such conduct is made explicitly or implicitly a term or condition of employment.
• Submission to or rejection of such conduct is used as the basis for decisions affecting an individual’s employment.
• Such conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment.
   

Employees are expected to conduct themselves in a professional and businesslike manner at all times. Conduct which may violate this policy includes, but is not limited to, sexually implicit or explicit communications whether in:

• Written form, such as cartoons, posters, calendars, notes, letters, e-mails.
• Verbal form, such as comments, jokes, foul or obscene language of a sexual nature, gossiping or questions about another’s sex life, or repeated unwanted requests for dates.
• Physical gestures and other nonverbal behavior, such as unwelcome touching, grabbing, fondling, kissing, massaging, and brushing up against another’s body.
   

This policy applies to all employees including managers, co-workers, and non-employees such as customers, clients, vendors, consultants, etc.

If you believe there has been a violation of the EEO policy or harassment policy based on a protected class, including sexual harassment, please use the following complaint procedure. WRF expects employees to make a timely complaint to enable the organization to investigate and correct any behavior that may be in violation of this policy.

Report the incident to your manager or Human Resources (HR). Non-employees should report their concerns to the HR Manager, who also serves as WRF’s Title VI & IX Coordinator. Should reports be made orally, the employee or non-employee is responsible for following up with a written report submitted to the same management official to whom the verbal report was made. HR will investigate the matter and take corrective action. Your complaint will be kept as confidential as practicable. If you prefer not to go to either of these individuals with your complaint or if either individual is the subject of your complaint, you should report the incident to the Chief Operating Officer.

WRF prohibits retaliation against employees and non-employees for filing a complaint under this policy or for assisting in a complaint investigation. If you perceive retaliation for making a complaint or your participation in the investigation, please follow the complaint procedure outlined above. The situation will be investigated.

If WRF determines that an employee’s behavior is in violation of this policy, disciplinary action will be taken, up to and including termination of employment. If WRF determines that a non-employee’s behavioris in violation of this policy, WRF reserves the right to sever the business relationship. WRF may also take less severe actions, when and as appropriate based on the facts and circumstances of each occurrence. Such actions may include, but are not limited to, requesting removal of non-employees from the applicable engagement team or project, requesting non-employees attend relevant training, requiring employees to attend relevant training, or other steps.

For questions or concerns, please contact Leila Paulson, Human Resources Manager and designated Civil Rights Coordinator at lpaulson@waterrf.org.

1. Introduction

All agencies that receive federal financial assistance must take adequate steps to ensure that persons with limited English proficiency receive the language assistance necessary to allow them meaningful access to services, free of charge.

Title VI of the Civil Rights Act of 1964 and Executive Order 13166, calls for guidelines for agency personnel to follow when providing services to, or interacting with, individuals who have limited English proficiency (LEP).

Additionally, Section 504 of the Rehabilitation Act of 1973 forbids public and private entities that receive financial assistance from any federal department or agency from excluding people with disabilities or denying them an equal opportunity to receive program benefits and services.

The purpose of Title VI of the Civil Rights Act of 1964 is to prohibit discrimination on the basis of race, color or national origin in federally assisted programs. The intent of the law is to ensure that all persons, regardless of their race, color or national origin, are allowed to participate in these federally funded programs.

1.1 Purpose

The Water Research Foundation (WRF) has established the following procedures to provide monitoring of Title VI compliance activities and complaint processing in all WRF programs and projects that receive federal funding.

1.2 Policy

WRF and its sub-recipients of federal funds will not:

1. Deny an individual service, or provide only inferior or discriminatory service, aid or benefits because of an individual’s race, color or national origin;
2. Subject a person to segregation or treat a person differently in regards to eligibility for and participation in services because of race, color or national origin;
3. Discriminate in any way against an individual in any program or activity that is conducted with federal funds.
    

2. Complaint Procedures

If you believe there has been a violation of the policy, please use the following complaint procedure. WRF expects employees and non-employees to make a timely complaint to enable the organization to investigate and correct any behavior that may be in violation of this policy. Complaints should be filed promptly and must be filed not later than one hundred eighty (180) calendar days after the alleged discrimination occurred.

Report the incident to your manager or Human Resources (HR). Non-employees should report concerns to the HR Manager, who also serves as WRF’s Title VI & IX Coordinator. Should reports be made orally, the employee or non-employee is responsible for following up with a written report submitted to the same management official to whom the verbal report was made. HR will investigate the matter and take corrective action. Your complaint will be kept as confidential as practicable. If you prefer not to go to either of these individuals with your complaint or if either individual is the subject of your complaint, you should report the incident to the Chief Operating Officer.

WRF prohibits retaliation against employees and non-employees for filing a complaint under this policy or for assisting in a complaint investigation. If you perceive retaliation for making a complaint or your participation in the investigation, please follow the complaint procedure outlined above. The situation will be investigated.

If WRF determines that an employee’s behavior is in violation of this policy, disciplinary action will be taken, up to and including termination of employment. If WRF determines that a non-employee’s behavior is in violation of this policy, WRF reserves the right to sever the business relationship. WRF may also take less severe actions, when and as appropriate based on the facts and circumstances of each occurrence. Such actions may include, but are not limited to, requesting removal of non-employees from the applicable engagement team or project, requesting non-employees attend relevant training, requiring employees to attend relevant training, or other steps.

When filing the complaint, the complainant should provide the following information:

1. Name, address and telephone number of the complainant;
2. The nature of the incident that led to the complainant to feel that discrimination was a factor;
3. The basis of the complaint (race, color or national origin);
4. Names, addresses and phone numbers of people who may have knowledge of the event; and
5. The date or dates on which the alleged discriminatory event or events occurred.
    

If the complainant is not satisfied with the resolution, an appeal process is available. An appeal request for review must be filed, in writing, within thirty (30) calendar days of the resolution of the complaint, with the HR Manager or Chief Operating Officer. The written appeal must include the complainant’s name, address, and telephone contact number. A statement of reason(s) why the complainant believes the denial of the complaint was inappropriate is recommended.

The coordinator will maintain a complaint log to show identifying information type and status of each complaint filed. When any investigation is concluded, the coordinator will keep a copy of the report on permanent file.

3. Limited English Proficiency (LEP) Policy

WRF is committed to providing quality services to all citizens, including those who do not speak English as their primary language, and who have a limited ability to read, speak, write, or understand English. These individuals may be considered Limited English Proficient, or “LEP,” and may be entitled to language assistance.

As a recipient of Federal funding, WRF must take reasonable steps to ensure meaningful access to its programs, projects, activities, and reports by LEP persons. The U.S. Department of Labor’s Office of the Assistant Secretary for Administration & Management recommends analyzing the following four factors to determine the level and extent of language-assistance measures required within the grantee’s area of responsibility[1]:

1. The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or grantee.
2. The frequency with which LEP individuals come in contact with the program.
3. The nature and importance of the program, activity, or service provided by the program to people’s lives; and
4. The resources available to the grantee/recipient or agency, and costs.

The intent of this policy is to find a balance that ensures meaningful access by LEP persons to WRF programs, projects, activities, and reports while not imposing undue burdens on WRF. Specific steps to be taken, in terms of translation or language interpretation, will depend on the specific situation at hand and at the specific time of the request, coordination with LEP individuals and the organizations that serve them, and analysis of WRF’s existing resources and the costs of providing language assistance.

For questions or concerns, please contact Leila Paulson, Human Resources Manager and designated Civil Rights Coordinator at lpaulson@waterrf.org. 

[1] See https://www.lep.gov/sites/lep/files/resources/lep_aug2005.pdf