XXI. EQUAL EMPLOYMENT OPPORTUNITY AND AFFIRMATIVE ACTION

A. POLICYAURA is committed to the full development of the human resources that support ourmissions. We strive to create and maintain a work environment in which people are treatedwith dignity, f airness, decency and respect. All employees, regardless of their positions,are covered by, and are expected to comply with, this policy and to take appropriate
measures to ensure that prohibited conduct does not occur. Management is expected tolead in developing and practicing fairness, appropriate behavior and providing a good work
climate for all staff.
AURA is an equal opportunity and an affirmative action employer. AURA complies with allapplicable federal, state and local laws prohibiting employment discrimination and expects
all individuals to conform to the spirit as well as the letter of all applicable laws andregulations.
AURA prohibits discrimination of any type and affords equal employment opportunities toemployees and applicants without regard to race, color, national origin, gender, gender
identity and/or expression, sexual orientation, age, religion, pregnancy, lawful politicalaffiliation, disability, veteran status, and/or any other protected class as may be legally
established in the jurisdictions in which our Centers/Sites are located. Prohibition against
discrimination extends to all personnel actions including:
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Recruitment
Employment
Promotion
Transfer
Training
Compensation
Benefits
Working Conditions
Termination and/or Layoff
Application of Policies

All employment decisions shall be consistent with the principle of equal employment
opportunity and only job-related qualifications will be required. All applicants possessing
the minimal qualifications for any vacant position will be considered.
Pursuant to Executive Order 13665, The Pay Transparency Act, AURA will not discharge
or in any other manner discriminate against employees or applicants because they haveinquired about, discussed, or disclosed their own pay or the pay of another employee orapplicant. However, employees who have access to the compensation information of other
employees or applicants as a part of their essential job functions cannot disclose the payof other employees or applicants to individuals who do not otherwise have access tocompensation information, unless the disclosure is (a) in response to a formal complaint orcharge, (b) in furtherance of an investigation, proceeding, hearing, or action, including aninvestigation conducted by AURA, or (c) consistent with AURA’s legal duty to furnish
information. 41 CFR 60-1.35(c)Revised May 18, 2018
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To accomplish the long-range objectives of its Equal Employment Opportunity/ AffirmativeAction (EEO/AA) Policy, AURA recognizes that continued affirmative action must be
undertaken. AURA’s employment practices will be periodically reviewed to ensure that job
opportunities are called to the attention of underutilized group members and that these
individuals are offered positions on the same basis as other applicants or employees.
Emphasis will be placed on seeking and encouraging applications from women, minorities,individuals with disabilities, and protected veterans with necessary qualifications andpotential.
Placement or promotion activities at all levels will be monitored to ensure that fullconsideration is given to all qualified employees from under-represented groups. Emphasis
will be placed on promotion from within. This provides opportunities for individuals in underrepresented groups to compete for placement or promotion at higher skill levels. AURA,
under its Affirmative Action Plan, will give special consideration to women, minorities,
individuals with disabilities and protected veterans for placement and/or promotion where
the individual Center’s/Site’s availability permits. AURA will take positive strides to employ,advance in employment, and otherwise treat persons covered under the Rehabilitation Actof 1973, as amended, and the Vietnam Era Veterans' Readjustment Assistance Act of1974, as amended, without discrimination.
AURA maintains written Affirmative Action Plans and reporting for Women and Minorities
as well as Individuals with Disabilities and Protected Veterans. These Plans and reports
contain detailed information regarding the specifics of communication, administration andevaluation of all aspects of AURA’s EEO/AA activities. They are available at eachCenter’s/Site’s Human Resources Office, are updated annually, and maintained for three(3) years. They are available for viewing by scheduling an appointment with the Center/Site
Human Resources Office. The reports are considered proprietary and confidential. Any
records on complaints, compliance reviews and other required reports are kept for at least
three years.
AURA Centers/Sites will seek out affirmative opportunities to provide training andopportunities to assist qualifying women, members of under-represented minority groups,individuals with disabilities and protected veterans who would otherwise not be offeredemployment or promotion. All employees are encouraged to increase their skills and job
potential through participation in available training and educational assistance programs.
AURA's policy invites all applicants and employees who believe themselves to be coveredby an Act and who wish to benefit under the Affirmative Action Program to identify
themselves. This information shall be voluntarily provided and will be kept confidential.
Refusal to provide this information will not subject the applicant or employee to any adverse
treatment and will only be used in accordance with the Acts and their regulations.
The program is administered at the AURA facilities in Chile under the customs and laws ofChile.

B.

EEO/Affirmative Action Responsibilities
1. The Center/Site Human Resources Managers are designated as the EEO/AA Program
Managers, and they are responsible to the AURA Center/Site Directors and the AURA
President for all phases of the AURA EEO/AA Program. The EEO/AA Program

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Managers shall:a.

Prepare, under the overall direction of AURA, Equal Employment Opportunity/
Affirmative Action (EEO/AA) policy statements and programs, to include programsfor Women, Minorities, Individuals with Disabilities and Protected Veterans.

b.

Establish short- and long-term EEO/AA goals.

c.

Prepare the reports required by local, state and federal regulations.

d.

Provide guidance and assistance to all AURA organizational elements in making theEEO/AA Program a model program.

e.

Disseminate information regarding AURA's program, both internally and externally.

f.

Maintain liaison with government organizations and organizations for individuals withdisabilities and protected veterans to establish and develop mutually beneficialrelationships;g.

Identify problems and problem areas and developing recommendations for solutions
by pursuance of methods for reasonable accommodations;h.

Audit employment and relevant procedures to ensure that the program is realisticand effective;i.

Keep management informed of the latest developments and status of the AURA
program by preparation of a formal annual report and informal interim reports asrequired;j.

Investigate complaints, should they occur, taking appropriate action, andmaintaining records in accordance with Federal, State, and local requirements;k.

Cooperate with the Department of Labor and supply any pertinent information tothem.

2. Each Center/Site Director will:a. Ensure the policy is applied without reservation to all actions within their
responsibility in regard to conditions and privileges of employment.
b. Ensure that procedures for monitoring opportunities for utilization of present skills of
employees are established and for direction of unnecessary or non-job-related
criteria from job qualification requirements.
c. Cause the AURA Grievance Procedure to be reviewed periodically to ensure it iscarried out in accordance with EEO/AA guidelines.
d. Develop a system for internal program evaluation to include progress reports to be
furnished to the EEO/AA Program Manager for compilation.
e. Ensure Center participation in local community efforts to improve conditions which
affect employability.
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f.

Assist the AURA EEO/AA Program Managers in dissemination of information, bothinternally and externally, identification of problem areas and helping to develop
solutions; andg. Investigate and attempt to correct the reasons for complaints, should they occur.

3. Each A U R A Center/Site Director will appoint a Diversity Advocate for the Center
and/or Site. The Advocate’s role shall be to serve as a leader to ensure that practices
and policies are in place and to advance AURA’s commitment to diversity within theAURA organization and throughout the astronomical community. The Advocate shallalso serve as the Center’s/Site’s main liaison with the AURA Committee on Workforce
and Diversity.

C.

DISSEMINATION OF EEO POLICY
The Affirmative Action Program includes procedures for the dissemination of AURA’sEEO/AA policy. The primary objective of this aspect of the program is to ensure awarenessand understanding of the program by all employees. It is understood that this is a crucial
factor in achieving the goal of Equal Employment Opportunity for AURA.
1. Internala. Each Center/Site will disseminate the EEO/AA Policy to all employees at the time ofhire as well as to managers and supervisors who are involved with the appointment,
transfer and promotion of personnel.
b. The AURA EEO/AA Policy will be posted and maintained on the AURA website.
c. Employee newsletters will contain a reminder that AURA is an Equal Opportunity
Employer.
d. Position descriptions will be established and reviewed as part of the performanceevaluation procedure to ensure they contain no language which may bediscriminatory.
e. AURA’s EEO/Affirmative Action policy and progress will be reviewed, at least
annually, with each Center’s/Site’s managers and supervisors. AURA's
commitment to the policy will be discussed during management, supervisoryand employee meetings.
f.

A copy of the Affirmative Action Plan will be available for employees andapplicants to review.

2. Externala. Dissemination of EEO/AA Policy includes publicizing the policy to organizations
within the community whose membership includes significant numbers of, or which
represent, minorities, women, individuals with disabilities and protected veterans.
Continuous contact with such organizations will be maintained by each Center
EEO/AA Program Manager for assistance in current recruitment and also to aid in
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maintaining the flow of applicants for future openings. All organizations contacted
will be advised on AURA's EEO/AA commitment to meeting hiring goals in fillingcurrent openings.
b. Additional recruiting sources will be cultivated as a part of each Center’s recruiting
program.
c. Employment advertising will make reference to AURA's Equal Employment
Opportunity/Affirmative Action policy and clearly convey AURA's desire to interest
all applicants.
d. All recruiting sources used by AURA will be advised in writing of the policy andurged to include women, minorities, individuals with disabilities and protectedveterans in their referrals.
e. AURA will request appropriate agencies for the handicapped and veterans to assist
in making known AURA's policy and will advise such groups of employmentopportunities.
f.

Reminders will be sent at least once each year to employment and recruitment
sources.

g. The policy will be included in all contracts and subcontracts that are for more than
$2,500.
h. Applicants may review the plan, which is available in the Center/Site Human
Resources Office.
i.

An annual report will be made stating utilization percentages of women, minorities,individuals with disabilities and protected veterans for each job category. Goals will
be set annually based on the availability of target group members. Results,problems, adverse trends or patterns obtained as a result of any of the above
procedures will be reported to the Center/Site Director, or a designee, and to theEEO/AA Program Manager(s).

j.

The EEO/AA Program Manager(s), or a designee, generally will review all
appointments and promotions of non-minorities or male candidates where aminority or female applicant is available in an underutilized job category.

DEFINITIONS
1. Individual With A Disability
For purposes of the Rehabilitation Act, an individual with a disability is anyone who has aphysical or mental impairment, which substantially limits one or more of their major life activities
or has a record of such impairment and is regarded as having such impairment. This isconsistent with Executive Order No. 11758, and pursuant to Section 503 of the Rehabilitation
Act of 1973, as amended, Public Law 92-112, and the 1974 amendments to the Act.
2. A Protected VeteranAccording to the Vietnam Era Veterans' Readjustment Assistance Act of 1974, as amended by
the Jobs for Veterans Act of 2002, a protected veteran is an individual who fits one of thefollowing classifications:
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Page 5a) A “disabled veteran” is one of the following: a veteran of the U.S. military, ground, naval or
air service who is entitled to compensation (or who but for the receipt of military retired pay
would be entitled to compensation) under laws administered by the Secretary of Veterans
Affairs; or a person who was discharged or released from active duty because of a serviceconnected disability.
b) A “recently separated veteran” means any veteran during the three-year period beginningon the date of such veteran’s discharge or release from active duty in the U.S. military,ground, naval, or air service.
c) An “active duty wartime or campaign badge veteran” means a veteran who served on active
duty in the U.S. military, ground, naval or air service during a war, or in a campaign orexpedition for which a campaign badge has been authorized under the laws administeredby the Department of Defense.
d) An “Armed Forces Service Medal veteran” means a veteran who, while serving on active
duty in the U.S. military, ground, naval or air service, participated in a United States military
operation for which an Armed Forces Service Medal was awarded pursuant to Executive
Order 12985.

ACCOMMODATIONS
Pursuant to Section 503 of the Rehabilitation Act of 1973, as amended, AURA and its
Centers/Sites will provide reasonable accommodation to individuals with disabilities to allow theindividual to fulfill the essential duties and responsibilities of the position. Individuals with disabilities
who are candidates for employment or existing employees are encouraged to inform the HumanResources Office if they require reasonable accommodation to apply for a job or perform a job.
AURA and its Centers/Sites will attempt to accommodate requests for reasonable accommodation
to the extent that the request does not impose an undue hardship on the organization. Individuals
are requested to respond to the following:
1. Specify the skills and procedures used or intended to b e used to perform the job
notwithstanding the disability and,2. Specify the accommodations the individual believes the organization could make which
would enable them to perform the job properly and safely, including special equipment,changes in the physical layout of the job, elimination of certain non-essential duties relating
to the job, or other accommodations.
Based on the requirements of the job and to ensure proper placement, AURA may require aphysical examination to be conducted on a prospective or current employee to evaluate requested
accommodations or restrictions on work or duties or any hazards that could exist for the individual
or co-workers. Supervisors and/or managers may be informed regarding restrictions on the workor duties of the person, any potential risks for the individual and/or co- workers and/or regarding
necessary accommodations. First aid personnel may be informed, when and to the extent
appropriate, if the condition might require emergency treatment.
For additional information, see the AURA policy titled, “Americans With Disabilities Act andReasonable Accommodation.”

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Policy Title and Number: B-XXI Equal Employment Opportunity and Affirmative Action
Name of Policy Owner: Human Resources
Policy History: Last version April 2014
Policy Approved By: AURA Regulatory Compliance Policy Committee
Date Policy Approved: May 18, 2018
Effective Date of Policy: May 18, 2018
Description of Revisions: Current version contains no material change to policy – wordsmithingfor clarity only.
Version # of Policy: 2.0
Next Scheduled Review Date: Two years from approval date or earlier, if there are changes in thelaw or policy requirements

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