Equal Employment Opportunity Policy

Dissemination Plan for EEO Program

Formal, written communication mechanisms have been established to publicize and disseminate HIRTA’s Equal Employment Opportunity (EEO) Program to its employees, applicants, and the general public.

Internal Dissemination

HIRTA provides a copy of the EEO Policy and Guidelines to anyone who requests one.

HIRTA’s employees and management staff are fully informed of the agency EEO policy and are provided updated and refresher materials through:

• Annual memo to all employees from the EEO Officer reaffirming HIRTA’s commitment to the EEO.
• Top management will meet semi-annually to discuss the EEO Program and its implementation.
• EEO and Harassment training provides awareness of this policy and is required for all HIRTA employees every four years. HIRTA conducts training every 2 years.
• EEO and Harassment training provides awareness of this policy and is required for anyone hired or promoted to a Supervisory or Management position within 90 days of appointment.
• Posting of EEO posters and policy statements in all HIRTA offices.
• EEO Policy and Complaint Procedures are posted on HIRTA’s employee portal.  
• An annual meeting will be held with all employees to seek input on the program implementation.

External Dissemination

• HIRTA’s EEO policies will be disseminated when outreach or advertising occurs to recruitment entities such as employment agencies, educational institutions, and minority and women’s organizations.
• All recruitment ads (including those placed in print or online via website or social media) will state that HIRTA is “an equal employment opportunity employer”.
  

Designation and Responsibilities of Personnel for EEO Program

CEO

The CEOs job description includes ensuring EEO Program requirements within the transit agency are implemented and in compliance as related to all Federal Transit Administration programs and advise the HIRTA Board of Directors on any EEO compliance issues.

Marketing and Communications Manager

This position will act as the Equal Employment Opportunity Officer. Their responsibilities will include:

• Assist in development of the EEO statement and the written EEO program.
• Assist in collecting and analyzing employment data, establishing goals and timetables, identifying problem areas and deficiencies, and developing the appropriate corrective action and programs to achieve goals.
• Design, implement, and monitor internal audit and reporting systems to measure program effectiveness and to determine where progress has been made and where proactive action is needed.
• Ensure the review of HIRTA’s nondiscrimination plan is shared with all managers to ensure the policy is understood.
• Concur with the hiring and promotion process.
• Periodically review employment practices policies (e.g., hiring, promotions, training), complaint policies, reasonable accommodation policies, performance evaluations, and grievance procedures.
• The EEO Officer will meet quarterly with the CEO and Management staff to informally discuss any on-going workforce changes (hiring, transferring, promotions), and any disciplinary actions taken. During these meetings, opportunity is given to discuss and recap EEO goals on hiring, especially underutilization in job applicants or employees.
• Serve as liaison between HIRTA, Federal, state, local governments, regulatory agencies, minority, women, disability organizations, and other community groups.
• Maintain awareness of current EEO laws, and ensuring the laws affecting nondiscrimination are disseminated to responsible officials.
• Investigate complaints of EEO discrimination.
• Oversee and ensure EEO training is provided for employees and managers. Assure all Managers understand HIRTA’s EEO policies and solicit their full support in achieving HIRTA’s goals and objectives.
• Advise employees and applicants of available training programs and professional development opportunities and the entrance requirements.
• Audit postings of the EEO policy statement to ensure compliance information is posted and up to date.

HIRTA Managers

Managers responsibilities in implementing the EEO Program include the following as benefits to their respective departments:

• Participating actively in periodic audits of all aspects of employment to identify and to remove barriers obstructing the achievement of specified goals and objectives.
• Holding regular discussions with other managers, supervisors, employees, and affinity groups to ensure agency policies and procedures are being followed.
• In conjunction with the EEO Officer, maintaining and updating the personnel database for generating reports required for the nondiscrimination program.
• Cooperating with the EEO Officer in review of information and investigation of complaints.
• Review qualifications of all employees to assure minorities, persons with disabilities and women are given full opportunities for transfers, promotions, training, salary increases and other forms of compensation.
• Inform all personnel that unlawful discrimination in any form will not be tolerated and will be dealt with appropriately.
• Encouraging employee participation to support the advancement of the EEO Program (e.g., professional development and career growth opportunities, posting promotional opportunities, shadowing, mentoring).

HIRTA Board of Directors

The HIRTA Board of Directors, which is responsible for hiring the CEO, must also follow all of the above responsibilities.

Assessment of Employment Practices

Assessment of Employment Practices

HIRTA relies upon the accuracy of all information obtained during the recruiting and hiring process. This includes but is not limited to previous employment history, educational history, background check data, etc. Any falsification or misrepresentation of facts may be sufficient cause for discipline up to and including termination.

Recruiting

HIRTA shall actively seek minorities, women and members of other protected groups for employment. In order to improve recruitment and increase the flow of minority and female applicants, HIRTA shall regularly contact local minority/female/veteran organizations when open positions are available. We will also recruit via Indeed, or similar employment websites, local newspapers when necessary, and Iowa DOT PTB (Public Transit Bureau) and IPTA (Iowa Public Transit Association) website as appropriate. HIRTA shall inform all recruiting sources of our EEO policy through distribution of open Job Opportunity Announcements, which states we are an Equal Opportunity Employer.

Employment and Selection

The minority/gender identities of applicants and new hires shall be reviewed periodically to assure that sufficient numbers are applying for jobs. All employees engaged in rendering hiring and promotion decision shall be trained to assure nondiscrimination in decision making. The hiring and promotion results shall be reviewed periodically to ensure there is no discrimination.

Applicants are invited to complete a voluntary form which includes self-identification for veterans and persons with disabilities during the application process. This information is kept separate from the application and is restricted for review by the CEO or for anonymous reports with quantitative data. The Application form contains the question, "Have you ever been convicted of a crime other than a minor traffic violation?" HIRTA uses both the answers to this question and the results of post-offer criminal background checks when making hiring decisions.

All screening mechanisms used shall be for purposes of determining an individual’s suitability for the particular job sought or to meet other lawful purposes. HIRTA shall not use any non-job-related screening mechanism that would have an adverse impact on minorities, females and members of other protected groups.

Applicants are selected for employment based on their ability to perform the essential functions of the position for which they are applying. In cases of a qualified applicants with disabilities reasonable accommodations will be made to assure no barriers to employment opportunities exist, absent undue hardship. HIRTA continues to make reasonable accommodations for employees when necessary, absent undue hardship.

Testing

All examinations shall be designed to fairly and impartially measure the fitness, aptitudes, skills, knowledge, abilities or other job-related qualifications of the applicant to properly and efficiently perform the duties of the position to be filled.

Training

HIRTA trains all staff on safety, policies and procedures, company standards, EEO Program, Emergency Preparedness and other in-house trainings. HIRTA does not discriminate against its employees for any reason. Depending on specific works duties, there may be specialized training for some employees, however, all employees have the same opportunity for training. If an employee feels they need additional training in a specific area they are expected to make their supervisor aware. All new hires are given orientation training, which includes a variety of things such as those mentioned in this section.

HIRTA encourages all employees, including those who are minority, have a disability and those whom identify as female to increase their skills and job potential through participation in training and education programs offered by community educational institutions, internal, or those offered by Iowa DOT, CTAA, APTA, NRTAP or through other transit related agencies.

Promotions

HIRTA encourages promotion from within the agency whenever possible. All openings will be posted on the employee portal and on office bulletin boards so employees are aware of, and may apply for, positions in which they are interested and for which they may be qualified. HIRTA does reserve the right to seek qualified applicants outside of HIRTA at our discretion.

To be considered for promotion, an employee must have successfully completed his/her initial probationary period, be employed in his/her current position for at least six (6) months, meet the qualifications for the vacant position and are not within a 6-month period of disciplinary action given. Members of underrepresented groups shall be given preference, when candidates are equally qualified.

Seniority

HIRTA does not base promotions, transfers, or layoffs on seniority.

Job Descriptions

HIRTA maintains a job description for each job category. New employees are provided a job description to sign in new hire orientation. Job descriptions are reviewed for accuracy when a position becomes available. All job descriptions are available on HIRTA’s employee portal for all employees to review and print. Job descriptions list the essential functions of the position and the necessary skills and abilities needed to perform the job.

Compensation and Benefits

HIRTA will review compensation and benefit packages for each employee classification in relationship to the compensation available in the private sector for like work.

Actual adjustment will be based on financial means available to HIRTA and as determined by the HIRTA Board of Directors, but all job classifications will be treated in an equitable manner in relationship to each other.

Currently, health and dental benefits, long and short-term disability, life insurance, Personal Time Off (PTO), floating holidays, paid holidays and bereavement leave are available to all full-time employees. Full-time is considered 40 scheduled hours per week. All employees receive IPERS.

Hours of Work and Work Breaks

The normal workweek for full-time employees shall be 40-hours and normally eight (8) hours per day. Part-time employees work schedules vary depending on workload and pre-negotiated schedules. Employees may be required to work in excess of their normal workweek.

Employees are allowed two (2) fifteen (15) minute paid breaks during the day or, based on the employee’s schedule i.e. Bus Operators, will have periodic breaks scheduled throughout the course of their day. This time, which shall be at the discretion of the supervisor or designee responsible for schedule changes. Abuse of work breaks is a violation of policy and can lead to discipline. There are times when it will be impossible to take time from an employee’s busy schedule to take a break; please be advised unused breaks may not be accumulated nor shall break time be utilized for early departure or late arrival during the course of the normal workday.

Unpaid lunch breaks are scheduled in a manner to best meet the needs of the work unit and the needs of the public. All employees, except as dictated by schedule, must take a minimum of one hour each workday for lunch breaks. This required break allows employees to return to the worksite or workstation rejuvenated.

Disciplinary and Termination Practices

The degree of discipline administered depends on the severity of the infraction. The supervisor is to evaluate the circumstances and facts as objectively as possible. The supervisor will then apply the most suitable form of discipline to the best of his/her knowledge and discretion. There are several types of disciplinary action designed to address problematic behavior at varying levels of severity. Supervisor’s need to use judgment as to which is the most appropriate level of discipline based on the totality of the circumstances.

• Verbal Counseling: The supervisor meets with the employee in private to assess action(s) and to counsel the employee as to how to correct the action(s). The incident and counseling session are documented with the employee signing the documentation to acknowledge its occurrence. The document is placed in the personnel file.
• Written Reprimand: The supervisor documents the nature of the infraction and discusses what further disciplinary action will follow if this or a similar incident is repeated. A copy of the written reprimand is given or sent to the employee. The employee signs the written reprimand to acknowledge receipt. The original document is placed in the employee's personnel file.
• Suspension: This form of discipline may be administered due to a significant infraction of standards of operation or for repeated violations. The supervisor shall set forth in writing the reasons for disciplinary suspension, the effective date and the duration of the suspension, and whether it is with or without pay. The employee is given a copy of the notice of suspension and the original is placed in the employee's personnel file. The employee shall sign the notice of suspension to acknowledge receipt. In the event an employee is involved in an activity that negatively reflects on HIRTA, or is involved in a serious complaint or suspected of a major rule violation, the CEO has the right to suspend the employee, with or without pay, pending investigation and final resolution. Such action is not a disciplinary suspension unless it is subsequently stated as such.
• Discharge: Prior to a supervisor taking action on the discharge of an employee, the supervisor must discuss his/her recommendations for discharge with the CEO or designee. If, in the opinion of the supervisor, the infraction is so severe as to necessitate immediate termination, the supervisor should take action by placing the employee on suspension with or without pay until circumstances are reviewed with the CEO or designee prior to final discharge action, which must be approved by the CEO.

In cases of termination, the employee is given or sent a copy of a written notice indicating the effective date of termination.

Exit Interviews

Any employee separating from HIRTA employment may request and shall be afforded the opportunity of an exit interview. Exit interviews allow opportunity for comments from employees about the agency and their position with HIRTA. If any written comments reveal EEO issues or discuss patterns of practice within HIRTA’s policies, those issues would be forwarded to HIRTA’s EEO Officer for review. 

HIRTA is committed to inclusivity and diversity in the workplace. We are also committed to investing in and retaining our employees, which means we continuously promote and provide ongoing training opportunities.

As indicated under the promotions section of this EEO Program Update, all employees may apply for open positions. HIRTA’s employment practice is to hire the most qualified applicant for the position and does not make employment decisions based on protected-class status. A number of other important and required trainings that impact day-to-day operations are afforded to employees. For example, we have harassment avoidance training on an annual basis. Bus drivers attend refresher and annual mandatory retraining. HIRTA Supervisors and Managers receive drug-free workplace training. All drivers receive distracted driving training.

Monitoring and Reporting 

An important part of any successful EEO program is the establishment of an effective and workable internal monitoring and reporting system. This system should: Assess the results of action plans taken since the last program submission and review accomplishments HIRTA will semi-annually review, with leadership staff, our EEO progress. This will enable us to identify areas of non-compliance and take corrective action in our EEO practices, if necessary.

The internal monitoring and reporting system will:

• Monitor, measure, and evaluate individual department implementation outcomes.
• Assess accomplishments and/or shortfalls.
• Identify areas which have failed to achieve the EEO goals.
• Provide a precise and factual database for future projections. The reporting system will provide documentation to support actions that affect hiring, training, transfers and promotions and any other area of underutilization in job applicants or employees. Management will be kept informed of program effectiveness. The creation of an EEO advisory work force may be an effective tool in this regard.
• Track and analyze complaints, to determine patterns, and corrective action.
• Review employees in each job category by race, national origin and gender who have applied for promotion or transfer and those promoted or transferred.
• Disciplinary action and terminations by race, national origin and gender will be assessed for negative patterns.
• Semi-annual visits to remote offices, provide a review of website and employee portal to ensure proper posting of EEO policy statement and any other required documents.
• Analyze in detail employment practices relating to recruitment, selection, salaries, promotions, terminations, standards of discipline, seniority, maternity/paternity leave, etc. Issues will be noted and a meeting held with management and hiring staff. 

1. Review analysis and provide report results to managers and hiring staff.
2. Discuss issues regarding EEO implementation, as well as, any other areas that need further focus. 
3. Determine a corrective course of action, which may include changes, clarification, training, etc., to ensure HIRTA is not operating contrary to its EEO guidance.
4. Prepare progress reports to submit to the HIRTA Board of Directors on EEO efforts and results.
5. HIRTA will maintain the following records documenting the EEO Meetings and/or Trainings:

• Agendas and sign-in sheets for EEO-related trainings or meetings
• Outcomes from EEO related meetings  
• Job postings and related advertisements discussed
• Cumulative records of applicants, hires, transfers, promotion, trainings, and terminations
• Documentation of EEO complaints and monitoring of the EEO complaint process.

Note: HIRTA does not have any union contracts.

Complaint Process

Any employee or applicant for a HIRTA position who feels they have been denied equal treatment for employment opportunities because of their race, color, national origin, sex, religion, disability, age or marital status may file an employment discrimination complaint. Employees and applicants are also protected from unwelcome sexual advances or conduct of a sexual nature that they find offensive or intimidating.

To file a complaint, applicants and current employees are encouraged to submit HIRTA’s EEO Complaint form or contact HIRTA’s EEO Officer, Danny Schnathorst at: HIRTA, 2824 104th Street, Urbandale, IA 50322 or DSchnathorst@ridehirta.com.

Investigating a Complaint

Investigation of Complaints received from employees or applicants regarding HIRTA’s employment practices will be addressed according to this procedure. The EEO Officer or their qualified designee will be assigned to investigate any complaint provided there is not a conflict of interest or the appearance of any conflict. Any investigator assigned to an EEO complaint will have received EEO investigative training and be otherwise qualified to conduct the investigation.

Conflicts of Interest

Independence and impartiality are key factors of a strong and effective EEO program. HIRTA will ensure that no conflicts of position or conflicts of interest, or the appearance of, with respect to the EEOO’s role. Therefore, in the event a complaint arises involving the EEOO or a member of the HIRTA administrative services department which includes those with human resource responsibilities, the EEOO designee will recuse themselves from the investigation and the HIRTA CEO will obtain a third-party external investigator to conduct an impartial and objective investigation. If HIRTA’s attorney provides legal expertise to the EEOO in the investigation of a case, they cannot then be the same attorney who represents the agency in an EEO complaint arising from the same case.

Resolution

Provided there is no conflict of interest, upon completion of the investigation the EEO Officer will evaluate the investigation outcome to determine what and if any action, is to occur. The individual who filed the complaint will be debriefed individually on the outcome of the investigation.

Alternatives

Employees and applicants may instead pursue their EEO complaint with the Iowa State Civil Rights Commission or the Equal Employment Opportunity Commission (EEOC). However, if an employee or applicant chooses to file a complaint with an external agency, HIRTA will temporarily hold the grievance/complaint filed under this Program, without action, until the external agency investigation is complete and a determination is made.

Tracking

HIRTA will track complaints to identify any trends or other data that may suggest a barrier in our employment practices. Tracking will also ensure complaints are processed in a timely manner and an appropriate resolution including any disciplinary action imposed is reached at the conclusion of the investigation. HIRTA will maintain a log that documents the name of the complainant, basis of the complaint(s), the protected group, date of initial contact, date of resolution, the resolution reached, and the name of the investigator.

The EEO Officer has the specific responsibility of investigating employee and applicant complaints of discrimination, including complaints of sexual harassment. The EEO Officer is available for informal consultation should an employee and/or manager desire information regarding a discrimination or harassment concern. The EEO Officer will meet with complainant to review the allegations, clarify issues, and obtain names of witnesses, if applicable. Some complaints may be resolved through discussions with appropriate personnel.

If the EEO Officer determines there are no issues of discrimination or harassment based on protected class, they will inform the complainant. In the event the EEO Officer determines a formal investigation is warranted, they shall conduct a full, prompt, thorough investigation of the allegations. Such investigation may include, but not be limited to, interviews with all parties named by the complainant and the respondent, as well as an analysis of relevant materials and records. Upon completion of the investigation, the EEO Officer shall present a written determination/finding to the complainant. This determination/finding may include a recommendation for corrective action. Early reporting is encouraged, because management's ability to investigate and act on reports diminishes with time.

NOTE: An alternative for filing a complaint with HIRTA is to file directly with the EEO Commission:

Phone: 1 (800) 457-4416 or (515) 242-5840

Appendix A – Description of Job Categories | Source: www.eeoc.gov

Officials and Administrators: Occupations in which employees set broad policies, exercise overall responsibility for execution of these policies, or direct individual departments or special phases of the agency's operations, or provide specialized consultation on a regional, district or area basis. Includes: department heads, bureau chiefs, division chiefs, directors, deputy directors, controllers, wardens, superintendents, sheriffs, police and fire chiefs and inspectors, examiners (bank, hearing, motor vehicle, warehouse), inspectors (construction, building, safety, rent-and- housing, fire, A.B.C. Board, license, dairy, livestock, transportation), assessors, tax appraisers and investigators, coroners, farm managers, and kindred workers.

Professionals: Occupations that require specialized and theoretical knowledge that is usually acquired through college training or through work experience and other training that provides comparable knowledge. Includes: personnel and labor relations workers, social workers, doctors, psychologists, registered nurses, economists, dietitians, lawyers, systems analysts, accountants, engineers, employment and vocational rehabilitation counselors, teachers or instructors, police and fire captains and lieutenants, librarians, management analysts, airplane pilots and navigators, surveyors and mapping scientists, and kindred workers.

Technicians: Occupations that require a combination of basic scientific or technical knowledge and manual skill that can be obtained through specialized post-secondary school education or through equivalent on-the-job training. Includes: computer programmers, drafters, survey and mapping technicians, licensed practical nurses, photographers, radio operators, technical illustrators, highway technicians, technicians (medical, dental, electronic, physical sciences), police and fire sergeants, inspectors (production or processing inspectors, testers and weighers), and kindred workers.

Protective Service Workers: Occupations in which workers are entrusted with public safety, security and protection from destructive forces. Includes: police patrol officers, firefighters, guards, deputy sheriffs, bailiffs, correctional officers, detectives, marshals, harbor patrol officers, game and fish wardens, park rangers (except maintenance), and kindred workers.

Paraprofessionals: Occupations in which workers perform some of the duties of a professional or technician in a supportive role, which usually require less formal training and/or experience normally required for professional or technical status. Such positions may fall within an identified pattern of staff development and promotion under a "New Careers" concept. Included: research assistants, medical aides, child support workers, policy auxiliary welfare service aides, recreation assistants, homemakers aides, home health aides, library assistants and clerks, ambulance drivers and attendants, and kindred workers.

Administrative Support (Including Clerical and Sales): Occupations in which workers are responsible for internal and external communication, recording and retrieval of data and/or information and other paperwork required in an office. Includes: bookkeepers, messengers, clerk-typist, stenographers, court transcribers, hearing reporters, statistical clerks, dispatchers, license distributors, payroll clerks, office machine and computer operators, telephone operators, legal assistants, sales workers, cashiers, toll collectors, and kindred workers.

Skilled Craft Workers: Occupations in which workers perform jobs that require special manual skill and a thorough and comprehensive knowledge of the process involved in the work that is acquired through on-the-job training and experience or through apprenticeship or other formal training programs. Includes: mechanics and repairers, electricians, heavy equipment operators, stationary engineers, skilled machining occupations, carpenters, compositors and typesetters, power plant operators, water/sewage treatment plant operators, and kindred workers.

Service-Maintenance: Occupations in which workers perform duties which result in or contribute to the comfort, convenience, hygiene or safety of the general public or which contribute to the upkeep and care of buildings, facilities or grounds of public property. Workers in this group may operate machinery. Includes: chauffeurs, laundry and dry-cleaning operatives, truck drivers, bus drivers, garage laborers, custodial employees, gardeners and groundkeepers, refuse collectors, construction laborers, park rangers (maintenance), farm workers (except managers), craft apprentices/trainees/helpers, and kindred workers.

Appendix B - EEO Job Categories at HIRTA

Job Group 1 – Officials and Managers

CEO

COO

Job Group 2 – Professionals

Customer Relations Manager

Operations and Fleet Manager

Volunteer Program Manager

Marketing and Communications Manager

Job Group 5 – Para-Professionals

Accountant

Operations and Fleet Manager

Job Group 6 – Administrative Support Workers

Dispatch  

Schedulers

Job Group 8 – Service

Bus Drivers