AFFIRMATIVE ACTION PLAN (AAP) FOR EQUAL EMPLOYMENT OPPORTUNITY LEE & RO, Inc. February 2005
CONFIDENTIALITY STATEMENT This Affirmative Action Plan (AAP) contains confidential information, which is subject to the provision of 18 U.S.C 1905. Copies of this AAP and all related documents, and supporting data will be made available on a loan basis to the U.S. Government upon the request of said Government on the condition that the Government hold them totally confidential and not release copies to any persons whatsoever. This AAP and other supporting documents contain confidential information that may reveal, directly or indirectly, the Company' s business plans. LEE & RO considers this AAP to be exempt from disclosure, reproduction, and distribution under the Freedom of Information Act upon the grounds that such material constitutes (1) the disclosure of personnel files which would constitute a clearly unwarranted invasion of personal privacy, which are exempt from disclosure under the Act; (2) confidential, trade secret or financial information which is exempt from disclosure under the Act; (3) investigatory records compiled for law enforcement purposes, the production of which would constitute an unwarranted invasion of personal privacy, which are exempt from disclosure under the Act; and as (4) matters specifically exempted from disclosure by statute, which are exempt from disclosure under the Act. Notice is hereby given of a request pursuant to 41 C.F.R. 60-60.4(d) that portions of this AAP be kept confidential. Therefore, LEE & RO, Inc. wishes to make it clear that it does not consent to the release of any information whatsoever contained in the AAP under the Freedom of Information Act or otherwise. If the U.S. Government, or any agency or subdivision thereof, is considering breaching the conditions under which this AAP was loaned to such government, or is considering a request of this Plan under the Freedom of Information Act, request is hereby made that the Government immediately notify the Chief Executive Officer of LEE & RO, Inc. and its counsel of any and all Freedom of Information Act requests by the Government or any other contemplated release of this Plan by the Government which relates to information obtained by the Government from LEE & RO. LEE & RO, Inc. further requests that everyone who has any contact with this AAP or its supporting appendices, documents, and other data, treat such information as totally confidential and that such information not be released to any person whatsoever. Retention of disclosure of information relating to identifiable individuals may also violate the Privacy Act of 1974. * * * *
LEE & RO, Inc. AFFIRMATIVE ACTION PLAN FOR EQUAL EMPLOYMENT OPPORTUNITY 1. POLICY It is the policy of this firm to provide equal employment opportunity to all persons without regard to their race, color, religion, ancestry, age, disability, medical condition, marital status, domestic partner status, sex, sexual orientation, or national origin, and to promote the full realization of equal employment opportunity through a positive continuing program. Our firm will assure that applicants are recruited and hired, and that employees are treated during employment without regard to their race, religion, sex, color, age or national origin. Equal opportunity and equal consideration will be afforded to all applicants and employees in personnel actions which include recruiting and hiring, selection for training, promotion and fixing rates of pay or other compensation. Implementation of this policy will provide a vehicle to employ minorities and females for full employment at all job levels through recruiting actions and by upgrading existing employees. Furthermore, it is our policy to coordinate the affirmative action program by seeking personnel from qualified minorities and providing direction to our staff to advance within the limits of each individual' s capabilities. LEE & RO, Inc. will not discriminate against any employee or applicant for employment because of physical or mental handicap in regard to any position for which the employee or applicant for employment is qualified. The company will take affirmative action to employ, advance in employment and otherwise treat qualified handicapped individuals without discrimination based on their physical employment upgrading, demotion or transfer, recruitment, advertising, layoff or termination, rates of pay or other forms of compensation, and selection for training. LEE & RO, Inc. will inform the State Labor Department, Local Job Service Office of our policy toward hiring of the mentally and physically handicapped and will list all job openings with the appropriate office. LEE & RO, Inc. will not discriminate against any employee or applicant for employment because he or she is a disabled veteran or veteran of the Vietnam Era in regard to any position for which the employee or applicant for employment is qualified. The company will take affirmative action to employ, advance in employment and otherwise treat qualified disabled veterans and veterans of the Vietnam Era without discrimination based upon their disability or veterans status in all employment practices such as the following: employment upgrading, demotion or transfer, recruitment, advertising, layoff or termination, rates of pay or other forms of compensation, and selection for training.
Affirmative Action Plan Page 2 LEE & RO, Inc. will inform the State Labor Department, Local Job Service Office of our policy toward hiring of the disabled veterans and veterans of the Vietnam Era and will list all job openings with the appropriate office. 2. DISSEMINATION OF POLICY Our equal employment opportunity policy is and will be communicated to all relevant audiences within and outside the firm. These include non-discrimination policy statements in our personnel manuals and memoranda, and employee information literature; posting of EEO posters on bulletin boards; periodic written and oral statements of policy from the firm' s officers to the management staff; discussion of policy and affirmative action plans in management meetings and development sessions; advertising in newspapers and technical journals, including those specifically directed to minority groups and audiences, oral and written policy statements to public and private employment agencies, to universities and schools from which we recruit employees, to community leaders and to community action groups and subcontractors. 3. RESPONSIBILITY FOR IMPLEMENTATION OF POLICY The Personnel Supervisor will be responsible for the implementation of our affirmative action policy and will direct our equal opportunity program. Her responsibilities will include (1) developing policy statements, affirmative action programs, internal and external communication techniques; (2) assisting in the identification of problem areas; (3) assisting managers in arriving at solutions to problems; (4) designating and implementing audit and report systems that will measure the effectiveness of the program, indicate a need for remedial action, and determine the degree to which the goals and objectives of the firm' s program have been attained; (5) serving as liaison between the company and enforcement agencies, minority organizations and community action groups; (6) keeping the executive management informed of the latest developments in the equal opportunity area. 4. IDENTIFICATION OF PROBLEM AREAS As of this date, LEE & RO, Inc. has a staff of 82 employees of which 38 are Caucasian, 32 are Asian or Pacific Islander, 3 are African-American, 9 are Hispanic, 0 are American Indian and 17 are female (see Table 1, Work Force Profile). Our recruiting area for engineers is national. In analyzing our utilization of minorities and females in each job category, we arrived at the following conclusions: a. Officers/Managers Discussion: The officers/managers of the firm, of which there are 6, are long-term professional employees elected to their position because of exceptional ability. They
Affirmative Action Plan Page 3 include engineering managers and department managers responsible for the accounting/administration, marketing, and regional offices. Presently there are no openings in this job category. Of the 6 officers/managers, one (or 17%) is female and two (or 33%) are minority. Conclusions: We have increased our minority and female managerial staff, but due to the current corporate structure, it is not realistic at the present time to establish a specific goal to increase these numbers further. b. Professional Discussion: Of the 44 professional employees, 5 (or 11%) are female and 19 (or 43%) are minority. Our multi-disciplinary professional staff is comprised of college graduates, most with advanced degrees, practicing in fields licensed by the State of California. Conclusions: We have recently increased our minority and female professional staff and will continue to attempt to recruit minority and/or female employees in this category as positions become available. c. Technicians Discussion: We have a total of 24 technicians, of which 75% are minority and 12% are female. Statistics taken from Labor Market Information for Affirmative Action Programs of minorities and females with the requisite skills indicate 45% are minority and 18% are female. Conclusions: We have recently increased the number of minority and female technicians employed at LEE & RO, Inc. and are engaged in an ongoing effort to recruit additional female technicians as positions become available. d. Administrative/Clerical Discussion: Of the 8 administrative/clerical staff, 63% are minority and 100% are female. Data obtained from the most current Labor Market Information for Affirmative Action Programs indicates that about 49% of the clerical labor market is minority and about 77% is female. Conclusions: While we do not anticipate an increase in administrative/clerical positions in 2005, should positions become available we will attempt to recruit additional minorities and females.
Affirmative Action Plan Page 4 e. Labor/Unskilled Workers Discussion: We currently do not have an employee in this classification. Conclusions: Should an opening become available, we will attempt to recruit a minority and/or female. 5. GOALS AND TIMETABLES Our current goal is to increase our female employment in the professional and technical job categories (as we have done in the past) and to increase minority employment in the administrative/clerical job category. The availability of qualified minorities or female professional engineering applicants and the current economic situation make setting timetables for the future somewhat problematic. During the coming year, we anticipate a modest increase in positions for the professional and technical categories. We will put maximum emphasis on recruiting minorities and females when we have available positions. 6. DEVELOPMENT AND EXECUTION OF PROGRAM a. Recruitment and Advertisement: As positions arise, our recruiting program will be conducted in such a manner as to ensure we reach minority groups and females. We plan to use minority recruiting sources and advertise in local publications such as the National Network for Minorities and the Community Watts News, which are oriented toward minority groups. Our advertisements in newspapers and other media will not (and do not) express a sex preference. Members of our current staff, particularly the minority and female staff, will be encouraged to actively seek out and refer applicants to fill job openings. b. Training: We will continue our policy of providing training to employees in each job category. Minority employees and females will be specifically encouraged to further their formal education and training. c. Personnel Actions: Personnel actions of every type including hiring, upgrading, promotion, transfer, demotion, layoff and termination will be periodically reviewed to ensure the action was taken without bias. The actions of supervisory personnel will be reviewed during supervisory meetings to ensure their support of the firm' s equal employment opportunity policy.
Affirmative Action Plan Page 5 d. Community Relations: Representatives of the firm will continue to work with the appropriate agencies and groups within the community to cooperate in the further development of community acceptance and the adoption of non-discrimination practices in employment. These include: Los Angeles Urban League Employment Service Society of Women Engineers (presently founding member of San Diego Scholarship Fund) Society of Hispanic Professional Engineers Association Asian American Architects/Engineers Association The Council of Black Professional Engineers 7. AUDIT, REPORT AND EVALUATION a. Job Openings: A list of applicants will be kept for each job opening. An informal record solely for statistical purposes will be maintained to identify minority and female applicants where practical. If a minority or female applicant is not hired, the reason will be recorded. b. Separation: A record of separation, and the reason for separation, will be maintained and female and minority group employees will be specifically identified. A thorough check will be made to ensure that discrimination did not enter into the separation. c. Promotions: A record of promotions by employee name and category will be maintained with female and minority employees specifically identified. Again, this information will be maintained solely for statistical purposes. Date: February 15, 2005 M. Steve Ro, President