AFFIRMATIVE ACTION PLAN

TABLE OF CONTENTS

PART ONE

PURDUE CALUMET AFFIRMATIVE ACTION PLAN

UNDER EXECUTIVE ORDER 11246 FOR WOMEN AND MINORITIES

I. INTRODUCTION AND STATEMENT OF POLICY 1

A. Description of the University 1

B. Purpose and Applicability of the Plan 1

1. Purpose 1

2. Applicability 1

3. Exclusion of Students 1

C. Reaffirmation of Policy 1

D. Definitions 2

E. Equal Opportunity Objectives 3

F. Legal Basis 3

1. Voluntary Goals 3

2. Access to the Plan 3

G. Cross References to Regulations 3

II. INTERNAL AND EXTERNAL DISSEMINATION 3

A. Internal Dissemination 3

1. Published Documents and Postings 3

2. Programs and Presentations 4

B. External Dissemination 4

1. Advertisements and Notices 4

2. Other Methods 4

III. IMPLEMENTATION AND RESPONSIBILITY 5

IV. UTILIZATION ANALYSIS 5

A. Job Classifications 5

1. EEO-6 Categories 5

2. Job Groups/Purdue Occupational Codes (POC's) 5

3. Special Situations 6

B. Determination of Availability 6

C. Utilization Analysis 7

1. Declaring Underutilization 7

2. Goals for Faculty Areas 7

3. Goals for Non-faculty Areas 7

D. Dissemination of Goals to Units 7

E. Corporate Selection Decisions 7

V. IDENTIFICATION OF PROBLEM AREAS 8

A. Workforce Array and Workforce Analysis 8

B. Job Group Analysis 8

C. Job Area Acceptance Range Analysis 8

D. Evaluation of Selection Process 8

1. Job Requirements and Descriptions 8

2. Referral Procedures 8

3. Pre-employment Inquiries 9

E. Recruitment 9

1. Appropriateness of Outreach 9

2. Review of Sources 9

F. Composition of Applicant Pools 9

1. Faculty 9

2. Non-faculty 9

G. Salary Studies 9

H. Benefits 9

I. Changes in the Workforce 9

1. Promotions and Transfers 9

2. Layoffs and Recalls 10

3. Terminations 10

4. Workforce Composition 10

J. Seniority Practices, Union Agreements, and Lines of Progression 10

K. Apprenticeship Programs 11

L. Training 11

M. Workforce Attitudes 11

N. Complaints and Grievances 11

O. Posters and Notices 11

P. Contract Compliance 11

Q. Corrective Action 12

VI. DEVELOPMENT AND EXECUTION OF PROGRAMS 12

A. Monitoring of Position Specifications 12

B. Distribution of Position Announcements 12

C. Selection Process: 12

1. Selection Procedures 12

2. Training of Selection Personnel 12

D. Recruitment and Referral Sources 12

E. Advertising 13

F. Publications 13

G. Social and Recreational Opportunities 13

H. Career Counselling 13

VII. INTERNAL AUDIT AND REPORT SYSTEMS 13

A. Personnel Information Systems 13

B. Purdue Applicant Retrieval System 13

C. Faculty Applicant Monitoring 14

D. Periodic Meetings and Progress Reports 14

E. Compliance Reviews 14

F. Biennial EEO-6 Report 14

G. Maintenance of Records 14

VIII. SUPPORT OF ACTION PROGRAMS 15

A. Minority Agenda Committee 15

B. Advisory Committee on Employment 15

C. Advisory Committee on Employee Relations and Career Development 15

D. Advisory Committee on Cultural Awareness 15

E. Affirmative Action Training Programs 15

F. Consideration of Minorities and Women Not in the Workforce 16

G. Community Involvement 16

IX. COMPLIANCE GUIDELINES 17

A. Sex Discrimination Guidelines 17

B. Religion and National Origin Guidelines 17

C. People with Disabilities Discrimination Guidelines 17

D. Disabled and Vietnam Era Veterans Guidelines 18

E. Age Discrimination Guidelines 18

PART TWO

PURDUE CALUMET AFFIRMATIVE ACTION PLAN

UNDER THE REHABILITATION ACT OF 1973

I. INTRODUCTION 19

A. Purpose 19

B. Reaffirmation of Policy 19

C. Definition 19

D. Responsibility 20

II. IMPLEMENTATION 20

A. Affirmative Action Statement 20

B. Education and Awareness Program 20

C. Internal Dissemination 20

D. Disability Self-Identification 20

III. PRACTICES AND PROCEDURES 21

A. General Requirements 21

B. Accommodations 21

C. Review of Physical and Mental Qualifications 22

D. Recruitment 22

E. Documentation 22

F. Dispute Resolution 23

PART THREE

PURDUE CALUMET AFFIRMATIVE ACTION PLAN

UNDER THE VIETNAM ERA VETERANS READJUSTMENT

ASSISTANCE ACT OF 1974

I. INTRODUCTION 24

A. Purpose 24

B. Reaffirmation of Policy 24

C. Definitions 24

D. Responsibility 24

II. IMPLEMENTATION 25

A. Affirmative Action Statement 25

B. Education and Awareness Programs 25

C. Internal Dissemination 25

D. Veteran's Self-Identification 25

III. PRACTICES AND PROCEDURES 25

A. Reporting and Requirements 25

B. Accommodations 25

C. Job Posting 26

D. Recruitment 26

E. Documentation 26

F. Dispute Resolution 27

APPENDICES

A. Executive Memorandum C-28

B. Purdue University Calumet - Utilization Analysis as of October 1999

C. Purdue University Calumet Net Change in Workforce in Chancellor's Office from

October 1998 to October 1999

D. Purdue University Calumet Net Change in Workforce in Academic Affairs from

October 1998 to October 1999

E. Purdue University Calumet Net Change in Workforce in Administrative Services from

October 1998 to October 1999

F. Purdue University Calumet Net Change in Workforce in Student Services from

October 1998 to October 1999

The Purdue University system includes several campuses under the direction of a single Board of Trustees. Purdue University Calumet (Purdue Calumet) is one the Purdue University system campuses. The Chancellor of Purdue University Calumet reports directly to the President of Purdue University.

Founded in 1946, Purdue Calumet is located in the northwest corner of Indiana. Purdue Calumet enrolls more than nine thousand students in more than 80 associate, bachelor's and master's degree programs in 16 academic departments. The 14 building commuter campus is situated on 180 wooded acres, about one hour from Chicago, Illinois.

Purdue Calumet is required to maintain an Affirmative Action Compliance Program for all employees. This plan is a part of that program.

This Affirmative Action Plan is published to reaffirm Purdue Calumet's continuing commitment to the principles of equal employment opportunity, and to increase Purdue Calumet's effectiveness in reaching affirmative action goals. This plan sets forth current and future action to be taken by the University concerning equal employment opportunities, and provides for implementation and monitoring of these actions.

This plan applies to all organizational units managed by or affiliated with the Purdue Calumet campus and reflects the plan adopted by the Purdue system.

Federal regulations do not mandate affirmative action for students; thus, they are excluded from this plan.

At its meeting on January 21, 1970, the Board of Trustees reaffirmed and reinforced Purdue University's general policy of equal opportunity by approving the following statement of policy and responsibility:

"Purdue University is committed to maintaining an inclusive community which recognizes and values the inherent worth and dignity of every person; fosters tolerance, sensitivity, understanding, and mutual respect among its members; and encourages each individual to strive to reach his or her own potential. In pursuit of its goal of academic excellence, Purdue University seeks to develop and nurture diversity. The University believes that variety among its many members strengthens the institution, stimulates creativity, promotes the exchange of ideas, and enriches campus life.

Acts of discrimination against any individual or group are wrong because they foster intolerance, incivility and intimidation. Purdue University does not condone and will not tolerate discrimination, harassment or intimidation of any individual in the University community for any reason. The University, through its actions, seeks to assure all its members of their rights to protections from the harmful effects of discrimination.

To meet its commitment under federal and state laws, Purdue University also promulgates policies and programs to ensure that all persons have equal access to its educational programs, employment opportunities, facilities, and all other University activities without regard to race, religion, sex, color, national origin, ancestry, disability, status as a Vietnam era veteran, or age. Additionally, Purdue University promotes the full realization of equal employment opportunity through its affirmative action program.

The President of Purdue University is charged with overall responsibility for nondiscrimination and equal opportunity."

The President has implemented this policy through a number of actions, including issuance of a revised Executive Memorandum C-28, Equal Employment Opportunity Program. A copy of C-28 is found in the Appendix .

Discrimination, as used in this program, refers to the process of illegally differentiating between people on the basis of group membership rather than individual merit. Systemic discrimination may be said to occur when unequal treatment results from "neutral" institutional practices that continue the effect of past discrimination. Individual discrimination may result when a person is subjected to unequal treatment on the basis of race, color, religion, age, national origin, ancestry, sex, disability, or status as a disabled or Vietnam era veteran.

The concept of equal opportunity proclaims the right of each person to apply and be evaluated for employment opportunities without regard to race, color, religion, age, national origin, ancestry, disability, or status as a disabled or Vietnam era veteran. It guarantees everyone the right to be considered solely on the basis of his/her ability to perform the duties of the job in questions, with or without reasonable accommodations.

The principle of affirmative action requires that aggressive efforts be made to employ and advance in employment women and minorities in areas where they are employed in fewer numbers than is consistent with their availability in the relevant labor market. Affirmative action also extends to persons with disabilities and disabled or Vietnam era veterans. The University's objective is to employ and promote the best person for the job. Consistent with this practice, affirmative action requires that where the candidates for a position appear to be equally well qualified, the person selected should be the one who will contribute to the achievement of affirmative action goals.

1. Recruiting, hiring, training, and promoting persons in all job classifications without regard to race, color, religion, national origin, ancestry, veteran's status, or physical or mental disability, age, or sex, except where age or sex is a bona fide occupational qualification.

2. Making decisions within all stages of the employment process that will further the principles of equal employment opportunity.

3. Ensuring that criteria for all personnel actions, including recruitment, hiring, promotion, granting of tenure, compensation, employee benefits, company sponsored training, selection for training, tuition assistance, recreation pro grams, transfer, demotion, layoff, return from layoff, discipline, termination, and all other terms, conditions and privileges of employment, are job related and realistic.

4. Applying vigorously the principles of affirmative action to correct problems if they arise and ensure equal opportunity in areas where underutilization of women or minorities are found.

This Affirmative Action Plan has been developed in accordance with the requirements of Executive Order 11246 (as amended), and the implementation guidelines published by the Office of Federal Contract Compliance Programs (OFCCP) in 41 CFR 60-2. The plan is also adopted and implemented in good faith, in conformity with, and in reliance upon, the language of the Equal Employment Opportunity Commission Affirmative Action Guidelines (29 CFR 1608.5).

Pursuant to 41 CFR 60-2.30, whenever the term "goal" is used, it is expressly intended that it should not be used to discriminate against any applicant or employee because of race, color, religion, sex, veteran status or national origin. All goals are voluntarily adopted in a good faith effort to support affirmative action efforts.

Purdue Calumet maintains and renews this plan annually. It is available for inspection Monday through Friday from 8:30 a.m. to 12:00 p.m. and 1:00 p.m. to 4:30 p.m. in the Affirmative Action Office, Lawshe Hall (room 329), in Hammond, Indiana. Questions about Purdue Calumet's Affirmative Action Compliance Program or about affirmative action should be referred to the Affirmative Action Office at 219-989-2571.

Major headings include citations to provide direct reference to pertinent sections of 41 CFR 60 (Chapter 41, Section 60 of the Code of Federal Regulations), or to other applicable rules and regulations. Citations are recapitulated in Appendix A. Some materials related to this plan are summarized in the Appendices.

The University disseminates its Affirmative Action/Equal Employment Policy both internally and externally utilizing the following procedures:

Purdue University's equal opportunity employment/affirmative action policy is annually communicated to all employees via the President's Executive Memorandum C-28. A copy of C-28 is provided for each new employee as part of the packet of introductory information.

The policy is included in the Faculty and Staff Handbook, an employee policies and procedures manual; Clerical and Service Staff Handbook, a handbook for clerical and service staff; Inside Purdue and other employee newspapers; the Business Procedures Manual; and the Academic Procedures Manual.

Equal employment opportunity posters and other required notices are displayed in locations where employment applications are received, where employment interviews are routinely conducted, and on public bulletin boards in every campus building.

Orientation programs for new employees and training workshops for current employees are conducted each semester by Personnel Services and the Affirmative Action Office in which the policy is discussed and responsibilities and procedures are explained.

The Chancellor and senior staff periodically emphasize this policy in meetings with directors, department heads, faculty and staff, and advisory groups including search committees.

Departmental staff meetings periodically include discussion of Affirmative Action/Equal Employment Opportunity (AA/EEO) to insure that all staff are aware of their responsibilities, and to determine if AA/EEO progress is being made.

The Affirmative Action Officer meets with Faculty Search Committees to ensure committee members understand Affirmative Action/Equal Employment Opportunity procedures and guidelines.

This Affirmative Action Plan is distributed annually to Purdue Calumet administrators and is used in Affirmative Action training programs.

Each advertisement of a vacant position placed by the University must state in clear distinguishable type: "An Equal Opportunity/Affirmative Action Employer."

Applicants are informed of the AA/EEO policy through posters displayed in the reception area of Personnel Services, and in materials included in the employment application packet.

The Purchasing Department sends written notification of the policy, including the equal opportunity clause to all sub-contractors, vendors, and suppliers doing business with Purdue Calumet (Purchasing Form 15W with attachments 15A and 15B).

The Physical Plant Department includes the university policy and equal opportunity clause in the general conditions of all contracts to be let for bid. When a contract is signed (AIA Form A101) those conditions are referred to under Article 7 in the contract text.

The Affirmative Action Officer communicates with organizations representing minorities, women, people with disabilities, Vietnam era and disabled veterans, and community agencies and leaders about the Affirmative Action Plan and Purdue Calumet's EEO policy.

In-house publications, such as Timeline, periodically include articles on minority and female employees and activities related to equal employment opportunity and affirmative action. The administration's weekly column in the Purdue Calumet Chronicle student newspaper occasionally contains similar information.

Copies of the Affirmative Action Plan are available at the Affirmative Action Office located in room 329 of Lawshe Hall.

Attention is given during preparation of handbooks, brochures and other publications to include information and pictures reflecting the participation of women, minorities, and people with disabilities in a wide range of campus activities. The Office of University Relations shares this responsibility.

Ultimate responsibility for compliance with applicable nondiscrimination and affirmative action laws and policies rests with the Board of Trustees.

Dr. James Yackel, Chancellor of Purdue Calumet, assumes responsibility, under the President of Purdue University, for the successful implementation of this policy, and delegates the following authority:

Ralph Ocon, is designated Affirmative Action/Equal Employment Opportunity Officer. In this capacity, he provides day to day responsibility, and general oversight and leadership for the University's overall compliance effort for all members of the university community, including compliance with Title VI, Title VII, Title IX, Section 504, the Age Discrimination regulations, Executive Order 11246, Americans with Disabilities Act, and state civil rights statutes.

Purdue Calumet's job classifications are determined through Personnel Services. A description of that determination is included below.

For the purpose of conducting meaningful workforce analyses, the Purdue Calumet staff is first grouped by occupational duties into segments having broad similarities. These macro-groupings, called EEO-6 categories, are defined in the "Higher Education Staff Information (EEO-6) Report for Public/Private Institutions of Higher Education" issued by the Equal Employment Opportunity Commission. The categories and their corresponding 2-digit identification codes used by Purdue Calumet are:

Within each major category, staff are subdivided into job groups, breaking them into segments with greater similarities, based on the criteria outlined in 41 CFR 60-2.11 (b) and five additional criteria:

a. Jobs within a group have similar content, promotional opportunities, and wage rates or salary patterns.

b. Jobs within a group exhibit similar patterns for utilizing males, females, and minorities.

c. In order to provide meaningful comparisons, job groups closely parallel the employment categories used in published data on the availability of minorities and women.

d. Job groups should take into consideration the reporting structure of the organization.

e. Each job group contains a number of employees sufficient for valid statistical analyses.

Graduate student assistants, designated as EEO-6 category 04, are included in certain workforce reports primarily to account for all staff listed on the Purdue University payroll. However, goals are not set for job groups in the student assistant category because student appointments are related solely to academic programs and are not part of the normal hiring procedures.

Individuals appointed as visiting faculty, post-doctoral research associates, or to other non-ladder (non-tenure track) positions labeled EEO-6 category 3 are included as part of the workforce summaries, but goals are not established for this group. By definition, the positions are of a limited duration. They are monitored by "AA FORM 7" which allows separate applicant flow data to be developed.

In accordance with Department of Labor guidelines, the following eight factors are considered in developing an estimate of the availability of women and minorities for each job group:

1. a. The percentage of minorities in the population of the labor area surrounding the facility.

b. The percentage of women among those seeking employment in the labor area or recruitment area.

2. The percentage of minorities and women among the unemployed in the labor area surrounding the facility.

3. The percentage of minorities and women in the total workforce in the immediate labor area.

4. The percentage of minorities and women among those having requisite skills in the immediate labor area.

5. The percentage of minorities and women among those having requisite skills within a reasonable recruitment area (i.e. local, regional or national depending on the job group).

6. The percentage of minorities and woman among those promotable or transferable within the facility.

7. The percentage of minorities and women at institutions providing training in requisite skills.

8. The percentage of minorities and woman among those at the facility whom the contractor can train in requisite skills.

Once availability has been determined, the utilization analysis is a simple yes or no question. Each job group's minority and female availability figure (a percentage) is compared to the percentage of minority and female incumbents in that job group. The "whole person" rule is applied in the analysis.

For faculty, the utilization analysis will determine whether minorities and/or women are underutilized in the various academic departments. Ladder rank, or tenure track, are considered separately from non-ladder rank, because no goals are set for non-ladder rank faculty.

Goals are established for all non-faculty job groups campuswide and in each unit where there is underutilization of minorities and/or women. Both Human Resources and each unit are made aware of unit and campus goals to be considered in their hiring efforts.

The responsibility for disseminating this information to department heads and to hiring supervisors rests with the Affirmative Action Office and Human Resources.

OFCCP Directive 830a1 (June 14, 1988) requires that affirmative action analysis and efforts will be focused where the authority and responsibility for filling positions is located.

Purdue is a multi-site university system which includes the regional campuses of Fort Wayne, Calumet, and North Central. While these campuses function with a degree of autonomy, as granted by the Board of Trustees, hiring decisions for certain high level positions are made from the President's or Executive Vice President and Treasurer's office in West Lafayette. When a vacancy occurs in the office of Chancellor at Purdue Calumet, the Council of Faculty Delegates can elect a committee to aid the President in filling the vacancy. Typically this committee assists in the recruitment of candidates, is involved in the interviewing process, and ultimately makes a recommendation to the President with regard to their ranking of the candidates. The President then submits a recommendation to the Board of Trustees for approval.

Purdue Calumet's Vice Chancellor for Administrative Services has a joint appointment with, and reports directly to, the Chancellor of the respective campus and the Executive Vice President and Treasurer located at the West Lafayette campus. Recruitment, interviewing, and selection activities are mutually coordinated between these University officers.

To identify problem areas, an in-depth analysis of several reports and processes is customarily made, paying particular attention to the patterns revealed by the distribution of minorities and women in various job groups. This section lists the analytical steps used to identify potential problem areas.

A. Workforce Array and Workforce Analysis (41 CFR 60-2.11(a)); (60-2.23(a)(1))

The workforce array provides a look at where women and minorities are and are not employed. This listing is mandated by OFCCP, and displays all job titles in each department ranked from lowest to highest paid within each EEO-6 category. Each job title line gives the salary range, the total number of incumbents, and the total number of male and female incumbents for each race/ethnic group. The workforce analysis is based on a November snapshot file.

This analysis is scanned for the underrepresentation of minorities and women in the job categories. Pay differences, concentrations, and focus job titles may also be determined from the workforce array.

Human Resources developed a classification for jobs called the job interest code. In this system, jobs are grouped on the basis of similar skills, similar pay, and potential upward mobility. The job interest codes are, in turn, clustered to form job groups (POC). The Job Group Analysis lists each employee in the job group, and is the report which shows the person's educational level and discipline along with job title and salary. This analysis is also completed during the yearly report generating cycle.

The Job Area Acceptance Range (JAAR) analysis is a comparison among Purdue Calumet's internal units of organization. It compares the participation rates for minorities and females in various individual units with their average participation rate in that EEO-6 category campus-wide. As with the workforce array and the job group analysis, the JAAR analysis is created and studied during the yearly report generating process.

Purdue Calumet observes the requirements of the Uniform Guidelines on Employee Selection Procedures (UGESP). Where adverse impact is found, the applicant flow data, selection criteria, and all elements of the selection process will be reviewed to ensure that only job-related, non-discriminatory factors are considered in making employment decisions, and that minorities and females have been considered. Selecting officials will be informed of the need to take corrective action when adverse impact is found in the recruitment or selection process.

Human Resources maintains a job description bank which lists the requirements for every regular position at Purdue Calumet and reviews them when there is a position vacancy and when other circumstances dictate. In addition, reviews may be requested by a unit supervisor or by the Affirmative Action Office.

Human Resources refers the credentials of the best qualified applicants, including those who may fulfill affirmative action goals, to the hiring department (unless the department does not desire screening of applicants for administrative and professional positions as specified in Executive Memorandum B-24).

Purdue Calumet will not identify any disability by examination at the pre-offer stage through job pre-tests, reference checks, interview forms/questions, and other information gathering procedures.

The Affirmative Action Office reviews recruitment efforts for faculty position vacancies. Recruitment of administra‑tive/professional staff is a joint responsibility of the hiring department and Human Resources. Recruitment efforts are judged on the scope of advertising for the position. Departments are to make a good faith effort in their recruitment processes, actively seeking out minorities and women, particularly in those areas where they are underutilized.

The Affirmative Action Office maintains a list of recruitment sources to assist departments in their hiring efforts. Departments, however, should be familiar with the principle sources specific to their particular area of expertise.

Applicant flow data for ladder rank, or tenure track, faculty is kept by individual departments on Applicant Flow Reports that are forwarded to the Affirmative Action Office for tabulation. Procedures are specified in EEO Memorandum 11 and in the Equal Employment Guide to Hiring.

Human Resources keeps information on the flow of all non-faculty applicants. These procedures are outlined in Executive Memorandum B-24 and Business Office Memorandum 173 on promotions, transfers, and job posting policies.

The Affirmative Action Office conducts an annual campus-wide faculty and non-faculty salary equity study. This analysis considers rank, tenure, service, time, department, and other variables to identify cases of possible salary inequity. Each department supervisor conducts a similar salary equity study within the department and corrective action is taken where justified.

When appropriate, the Affirmative Action Officer will meet with the benefits administrator or designee to ensure that protected class members are equally informed of relevant aspects of the benefits program and to identify aspects of the program most advantageous to protected class members.

I. Changes in the Workforce (41 CFR 60-2.23(a)(4); (60-2.22(b)(5)); (60-2.23(b)(2))

It is Purdue's policy to encourage transfers and promotions to further employee growth and development. Whenever a regular vacancy occurs, including promotion and transfer opportunities, the department head and/or supervisor must make this known to his/her regular staff members by the most effective means. If the position cannot be filled from within the department, it must be posted through Human Resources.

The Affirmative Action Office monitors layoff and recall proceedings to ensure fair application of those procedures. In addition, all employee areas are analyzed yearly to identify areas of adverse impact.

Terminations are monitored by Human Resources and the Affirmative Action Office.

a. The total workforce (headcount) decreased by 75 persons to 970. The number of females decreased by 11 and the number of minorities decreased by 6.

b. The number of women increased in 4 of the 10 EEO-6 categories, while minorities increased in 2 of the 10 categories. The overall minority percentage of the workforce increased from 21.67 to 21.5 campuswide.

c. Compared to Fall 1998, the number of Blacks decreased by 3, Hispanics increased by 3 Asians increased by 5 and Native Americans decreased by 1.

d. The number of female faculty increased, wit h 1 more woman in tenure-track positions this year (from 91 to 92). The number in non-ladder positions decreased from 123 to 105.

e. In Fall 1999, minority staff were distributed as follows in the EEO-6 categories:

African Americans comprised 5% of faculty, 11% of executive/managerial, 14% of professional, 14% of clerical, 8% of technicians, 7% of skilled crafts, and 34% of service/maintenance.

Hispanics comprised 4% of faculty, 7% of executive/managerial, 6% of professional, 14% of clerical, 3% of technicians, 25% of skilled crafts, and 21% of service/maintenance.

Asian/Pacific Islanders comprised 9% of faculty, 2% of executive/managerial, 0% of professional, 0% of clerical, 2% of technicians, 0% of skilled crafts, and 0% of service/maintenance.

Native Americans comprised 0% of faculty, 0% of executive/managerial, 0% of professional, 0% of clerical, 0% of technicians, 0% of skilled crafts, and 2% of service/maintenance.

J. Seniority Practices, Union Agreements and Lines of Progression (41 CFR 60-2.23(a)(6))

Purdue Calumet has no seniority system, no current union contracts, and maintains no lines of progression.

All training programs are open to participation by women and minorities. Human Resources normally conducts an annual review of Purdue Calumet sponsored training activities to ensure that women and minorities receive equal access.

Emphasis continues to be given to creating a hospitable environment for minorities and women. Organizational units are urged to include activities which focus on valuing diversity in their unit action plans.

The Affirmative Action Officer will meet periodically with the representative segments of the Purdue Calumet workforce at all levels, as well as with women and minorities, to assess the general pattern of workforce attitude in regard to equal employment opportunities and affirmative action. Though separate from the annual goal-setting meetings, these meetings will also include senior administrators.

All employees have access to the University grievance procedures as outlined by Executive Memorandum C-19 for academic personnel, Executive Memorandum B-37 for Administrative/Professional Staff, and Business Office Memorandum 137 for Clerical/Service staff.

Employees bringing complaints alleging discrimination should use the regular procedure established for filing grievances, as modified by Executive Memorandum B-29. In these cases the Affirmative Action Office will participate in investigating and resolving the issue.

Complaints alleging harassment are processed in accordance with Executive Memorandum C-33 and the Interim Procedures for Handling Complaints of Sexual Harassment, issued January 22, 1996. The Chancellor is responsible for overseeing and coordinating enforcement of policies and procedures that deal with sexual harassment for Purdue Calumet.

The Affirmative Action Office monitors complaints or requests for assistance and pursues any patterns or trends which suggest areas requiring remedial actions.

Required posters and notices with information on equal employment and affirmative action policies are placed in all campus buildings. Human Resources and the Affirmative Action Office annually distributes a memorandum to all building deputies requiring them to conduct routine checks of employee bulletin boards and other relevant areas for required affirmative action posters and notices.

Purdue seeks, identifies, and encourages women and minority owned and operated firms to participate in providing Purdue with goods and services. However, no specific goals or set-asides are established for University purchases and contracts.

Where problem areas are identified, necessary steps will be taken to correct the situation and remedial plans developed.

Human Resources reviews all non-faculty position specifications for job-relatedness and non-discrimination on the basis of race, color, religion, national origin, veteran status, disability, age, or sex, except where age or sex is a bona fide occupational qualification.

Each academic department is responsible for monitoring its respective faculty job specifications for job-relatedness and non-discrimination. The Affirmative Action Office assists in the evaluation processes in both areas.

Human Resources and the Affirmative Action Office monitors each position announcement for an adequate search or recruitment plan and also checks for compliance with equal employment opportunity and affirmative action guidelines and disclaimers.

Each advertisement and search plan is also reviewed to see that it includes mechanisms likely to reach protected class members. When effort appear inadequate, the Affirmative Action Officer immediately calls the search chair or department head to urge additional and/or alternative strategies.

The weekly "Position Vacancy Notice for C/S and A/P Staff" lists current openings posted through the Purdue University system Office of Human Resources and is distributed to all Purdue system departments, posted in public areas to more than 40 off-campus agencies and organizations throughout the state to reach minority groups.

Training and experience summaries have been established for the ranking and referral of applicants with administrative, technical or service job interests. The summaries rely on job specification and a comparison of each eligible applicant's work experience, education, skills, knowledge, and training. The rating system reflects Purdue Calumet's commitment to affirmative action by supporting the referral of minorities and females.

Deans, department heads and other unit managers responsible for making hiring decisions are taught equal employment opportunity requirements by Human Resources and the Affirmative Action Officer. Also, the Affirmative Action Officer meets with Faculty Search Committees to review EEO and Purdue Calumet guidelines and procedures. The Equal Employment Opportunity Guide To Hiring contains suggestions and guidelines for interviewing and hiring procedures. This booklet is available from the Affirmative Action Officer.

The Affirmative Action Office and Human Resources maintain a list of recruitment and referral sources by female and minority classification and academic discipline. The number of these sources grows through networking, personal contacts, and the identification of appropriate organizations which advocate minority and female opportunities in employment.

The Affirmative Action Office and Human Resources advise and assist schools or departments with wording and tone which might have greater appeal for women and minorities.

Advertisements are prepared by the respective school or department and channeled through Human Resources before being sent to Purchasing. The Affirmative Action Officer monitors all ads for inclusion of the statement: "An Equal Opportunity/Affirmative Action Employer."

University Relations ensures that University publications contain the phrase "Equal Opportunity/Equal Access University." This office also checks to see that where there are pictures of students, staff, or visitors, there is a balanced representation of women, minorities, and people with disabilities.

For all university sponsored social and recreational functions, Purdue Calumet offers equal opportunity to all employees without regard to race, color, religion, national origin, ancestry, veteran status, disability, age, or sex. Where segregation is necessary by sex, for example locker rooms or rest rooms, facilities will be substantially equal for males and females.

The Affirmative Action Officer will periodically monitor career counseling activities to determine if a significant number of protected class members are enrolling in these programs and to ensure that counseling sessions address informal lines of progress, upward mobility, and transfer opportunities which enhance development for protected class members.

Human Resources maintains current data on all Purdue Calumet employees gathered from several sources to update records, including information on new employees, changes in status, salary adjustments, and terminations. The content validity of the data is the responsibility of Human Resources.

Stored data are composed of personal and historical information as well as current employment records. The personal information includes sex, race, or ethnic background, age, veteran status, and disability if known. Human Resources maintains both microfiche and paper records.

The Purdue University system of Human Resources maintains records of non-faculty vacancies and applicants, and refers applicants who meet the minimum qualifications to supervisors seeking to fill vacancies. When a non-faculty unit has a vacancy in a category where there is an affirmative action goal, Purdue Applicant Retrieval System conducts a special search of the applicant pool to ensure that women and minorities who meet the job criteria are referred to the hiring supervisor.

All data are used to support the non-faculty applicant flow analysis. The data consist of race, sex, applicants referred, finalists, those offered positions, and those hired. These data and procedures also provide an audit trail of all referrals. The validity of this information is the responsibility of Personnel Services.

The employment search process for faculty vacancies is conducted by the employing department. The Affirmative Action Officer provides information to departments regarding affirmative action guidelines and collects and reviews data submitted for each vacancy.

The Equal Employment Opportunity Guide to Hiring provides an explanation of goals and goal-setting processes, recruitment suggestions and alternatives, rationale and instructions for full documentation of the hiring process, explanation of affirmative action reporting forms and their timing, employment interview guidelines, and a description of the monitoring processes. All faculty vacancies are reported, including non-ladder (non-tenure track) faculty. The non-ladder faculty are monitored using Form 7, even though they are not included in the goal-setting process.

Several safeguards are built into the monitoring system to ensure that all vacancies are recorded and reviewed. First, employment ads which require a publication fee must go through Purchasing, where wording is checked and problems referred to the Affirmative Action Officer before payment is authorized. The Affirmative Action Officer meets with Faculty Search Committees to review EEO and Purdue Calumet policies and procedures. The Affirmative Action Officer also reviews closing reports on vacancies and contacts departments directly when additional information is needed. When a consistent pattern of problems occurs in any given school or department, the Affirmative Action Officer contacts the respective dean and department head to resolve the problem.

The Purdue University system Affirmative Action Office holds meetings semi-annually with regional campus officers, including Purdue Calumet, to share information, concerns, and reports of progress

Periodic reviews are conducted by the Office of Federal Contract Compliance Programs (OFCCP) to determine whether Purdue Calumet is in compliance with Executive Order 11246. Prior to the award of a non-construction contract of one million dollars or more, a compliance review must be conducted and Purdue Calumet must be found in compliance or sign an agreement toward that end.

Title VII of the Civil Rights Act of 1964, Section 709(c), requires institutions of higher education to collect and maintain records necessary for the completion of the higher education staff information report (EEO-6), and to file that report every other year with the Equal Employment Opportunity Commission. This report covers all full-time and part-time staff and applicants in the institution. It also reflects the identical data used in the Affirmative Action Program.

Human Resources, in West Lafayette, provides data for the Affirmative Action Officer, who compiles the EEO-6 report. The report period covers October 1 through September 30 in odd-numbered years.

All records dealing with recruiting, hiring, promotion or termination are kept a minimum of two years. Included are other documents relating to compliance with applicable non-discrimination and affirmative action requirements. All records are maintained in accordance with the Federal Privacy Act and the Indiana Access to Public Records Law as referred to in Executive Memorandum C-2.

Purdue Calumet provides additional support for its affirmative action program through campus and community activities designed to raise public awareness of equal employment opportunity and affirmative action. The following list of activities is representative of such activities. (41 CFR 60-2.13(i));(60-2.26)

On January 25, 1989, the Minority Agenda Committee was established to encourage the development of a friendly campus climate conducive to the nurturing and support of every student, staff and faculty member so that each may achieve his/her full potential. The Minority Agenda Committee meets its charge by:

- address the issues of identifying and selecting qualified minority candidates for positions at Purdue Calumet.

- increase the minority hiring by facilitating the exchange of information about minority candidates and available positions.

- provide suggestions about programs and workshops relating to employment practices.

The Advisory Committee on Employee Relations and Career Development was established to:

- address the issue of cultural diversity as it relates to all members of the University Faculty and staff.

- recommend the creation of approaches to encourage the achievement of personal and professional goals and growth.

The Advisory Committee on Cultural Awareness was established to provide awareness programs dealing with cultural and ethnic concerns.

The Affirmative Action Office and Human Resources conducts training workshops for Purdue Calumet employees on various topics related to preventing and dealing with employment discrimination on a annual basis. Workshops held included the following topics:

In addition, the Affirmative Action Officer meets with faculty search committees to ensure committee members understand Affirmative Action/Equal Employment Opportunity procedures and guidelines.

F. Consideration of Minorities and Women Not in the Workforce (41 CFR 60-2.13(j))

Purdue Calumet will contact minorities and women not currently in the workforce having requisite skills who can be recruited through affirmative action measures. Purposeful outreach is being undertaken at all levels of employment.

1. Humane Resources distributes job notices to community groups representing minorities, women, persons with veteran status and the disabled.

2. Humane Resources distributes job notices to the Indiana Department of Employment and Training Services.

3. The Chancellor, Vice Chancellors, deans, department heads, and the Affirmative Action Officer travel to relevant regional and national meetings and conferences. Current employees are encouraged to identify colleagues through their community associations, professional affiliations, and social activities.

4. The Affirmative Action Office and Human Resources make presentations to local community centers, high schools, and interest groups whose memberships are likely to aid affirmative action efforts.

The Affirmative Action Officer is actively involved in community relations programs in support of Purdue Calumet's Affirmative Action Program through presentations to community groups on request both on and off the Purdue Calumet campus. The Affirmative Action Officer serves as a resource person to community groups or individuals requesting information.

Executive Memorandums C-28 and C-33 explains and summarizes the University’s commitment to Equal Employment Opportunity and Affirmative Action. These policies also provide guidelines for the university in the following areas:

It is Purdue Calumet's policy not to discriminate on the basis of sex in any term or condition of employment, benefits, training and promotional opportunities, and wages and hours.

Vigorous recruitment efforts will be made to attract female applicants to all job levels, particularly in areas which have an affirmative action goal or which have shown historical patterns of female underutilization. All employment practices apply equally to members of either sex. No difference is made between males and females in terms of retirement age for any job.

Women are not penalized in their employment because of marital status or time spent away due to childbearing or related medical conditions which are treated the same as any other temporary disability and same or equal status is guaranteed upon return from such leave.

Equal Opportunity Memorandum 12 Non-discrimination in Employment Practices on the Basis of Sex provides guidelines for the administration of these policies. Furthermore, Purdue's Executive Memorandum C-33 specifically spells out the University's policy on sexual and other forms of harassment. Harassment on the basis of gender or sexuality is not tolerated. The Affirmative Action Office and Human Resources both offer counseling for employees with these or related concerns.

Purdue University's equal employment opportunity policy continues to cover discrimination on the basis of religion or national origin. Purdue Calumet, as part of the Purdue system, is subject to this policy.

Purdue University hiring guidelines, by which Purdue Calumet is bound, expressly state that these characteristics are to have no bearing on any aspect of the employment process, and in fact should not be explored with an applicant in any job search, interview, or informal conversation.

Equal Employment Memorandum 13 Non-discrimination on the Basis of Religion or National Origin explains Purdue University's commitment to these ideals and provides guidelines for the administration of this program. Purdue Calumet, as part of the Purdue system, is subject to the provisions of Equal Employment Memorandum 13.

Purdue University, where feasible and where no undue hardship exists, provides reasonable accommodation to the religious observance or practices of an employee or prospective employee, including reasonable accommodation to the religious observances or practices of an employee who regularly observes Friday evening and Saturday, or some other day of the week as his or her Sabbath, and/or who observes certain religious holidays during the year and who is conscientiously opposed to performing work or engaging in similar activity on such days. In determining the extent to which hardship might exist in accommodating the religious observance or practice of an employee or a prospective employee, Purdue University will consider at least the following factors: business necessity, financial costs and expenses, potential for minimizing personnel problems. This policy is observed by Purdue Calumet as a part of the Purdue University system.

A Purdue University system task force to develop and coordinate implementation of the Americans with Disability Act (ADA) of 1990 was formed in early 1992. Interim guidelines for handling complaints under the ADA were issued in January, 1992. Purdue Calumet participates in the actions of this task force through its own Americans with Disabilities Act Committee. This committee also makes recommendations to the Chancellor about issues concerning persons with disabilities that affect the Purdue Calumet campus. Purdue Calumet's Affirmative Action Officer is a member of this committee.

Purdue Calumets Affirmative Action plan is also a statement of compliance with Section 402 of the Vietnam Era Veteran's Readjustment and Assistance Act of 1974. Significant changes concerning affirmative action and veterans are communicated to employees and applicants. The University lists all suitable openings with the local office of the Indiana Department of Employment and Training Services (IDETS). Purdue invites all applicants and employees who believe themselves to be covered under this plan to identify themselves as such on Affirmative Action Form 2 (for faculty) or the Human Resources Form 1A (for non-faculty).

In accordance with the amended Age Discrimination in Employment Act of 1967, the Age Discrimination Act of 1975, and Executive Order 11141, it will continue to be Purdue University and Purdue Calumet policy not to discriminate on the basis of age in any term or condition of employment, benefits, training and promotional opportunities, terminations, and wages and hours.

The following document is a written interpretation of Purdue Calumet's non-discrimination and affirmative action policy for the purpose of complying with Section 503 of the Rehabilitation Act of 1973. Responsibility for implementation falls under the Office of the Chancellor.

It is the policy of Purdue University Calumet that no applicant or employee shall be discriminated against because of any physical or mental disability with regard to any position for which the individual is qualified. The written Affirmative Action Plan is designed to employ, advance in employment, train, and otherwise treat people with disabilities without discrimination based on any physical or mental disability.

The University is committed to the elimination of any policy or practice which has the effect of discriminating against people with disabilities. Purdue Calumet is convinced that every individual is entitled to an opportunity equal to his or her abilities.

Considerate treatment of applicants and employees is essential to good human relations and the development of good moral among employees. These practices directly affect and improve the quality of employment at Purdue Calumet and create the kind of atmosphere which fosters a successful operation.

Purdue Calumet realizes that an individual with a disability is not a liability and is committed to providing people with disabilities the opportunity to grow, become employed, participate in activities, and benefit from programs at all levels within the institution.

The University's non-discrimination policy covers all aspects of employment. Affirmative action obligations imposed by the Rehabilitation Act of 1973 require the University to employ and advance in employment qualified individuals with disabilities at all levels of employment. The obligations apply to all employment practices including, but not limited to wages, company sponsored training, selection for training, education tuition assistance, transfer, demotion, layoff, return from layoff, recreation programs, recruitment, hiring, promotion, granting of tenure, compensation, employee benefits, discipline, termination, and all other conditions, privileges of employment, or other employment benefits.

Section 7(6) of the Rehabilitation Act defines the term "handicapped individual" as "any person who (1) has a physical or mental impairment which substantially limits one or more of such person's major life activities, (2) has a record of such impairment, or (3) is regarded as having such an impairment."

"Life activities" may be considered to include communication, ambulation, self-care, socialization, education, vocational training, employment, transportation, and adapting of housing, etc. For the purpose of Section 503 of the Act, primary attention is given to those life activities that affect employability.

The phrase "substantially limits" means the degree that the impairment affects employability. An individual with a disability who is likely to experience difficulty in securing, retaining, or advancing in employment, would be considered substantially limited.

The phrase "has a record of such an impairment" means that an individual may be completely recovered from a previous physical or mental impairment. It is included because the attitude of employers, supervisors, and co-workers toward individuals with an impairment may result in an individual experiencing difficulty in securing, retaining, or advancing in employment. The mentally restored and those who have had heart attacks or cancer, often experience such difficulty. Also, this part of the definition would include individuals who have been erroneously classified and may experience discrimination based on this wrong classification. This group may include persons such as those who have been wrongly classified as mentally retarded or mentally restored.

The phrase "is regarded as having such an impairment" refers to those individuals who are perceived as having a disability, whether an impairment exists or not, but who, because of attitudes or for any other reason, are regarded as having a disability by employers, or supervisors who have an affect on the individual securing, retaining, or advancing in employment.

The responsibility for the Affirmative Action Plan under the Rehabilitation Act of 1973 is under the Chancellor, Dr. James Yackel, who has delegated this responsibility for day to day operations to the Affirmative Action Officer, Ralph Ocon.

Each publication produced by the University contains a non-discrimination statement. Advertisements for faculty or non-faculty positions contain the statement "An Equal Opportunity/Affirmative Action Employer." The Affirmative Action Office checks for the statement in faculty advertisements and Personnel Services checks non-faculty advertisements. Publications pertaining to special events, programs, and activities contain the statement "Equal Opportunity/Equal Access University."

Cooperation with employees with disabilities is an essential part of the successful implementation of the University's Affirmative Action Plan. The Affirmative Action Office, and Human Resources provides training to educate employees concerning their responsibility to successfully integrate people with disabilities into the workforce.

Notification of the University's obligation to take affirmative action under the law is made available to all employees through the Affirmative Action Office. Required posters explaining the law and providing information on federal agencies to contact in regard to questions or complaints are posted by building deputies.

The Affirmative Action Plan under the Rehabilitation Act of 1973 is updated each year and is available for inspection Monday through Friday between 8:30 a.m. to 4:30 p.m. in the Affirmative Action Office, Lawshe Hall, Hammond, IN 46323.

Each March, an Employee Information Review Form is distributed to provide the opportunity for employees to voluntarily review and update their personnel records. A copy of this form is available from Human Resources. Information received from this form pertaining to a disability is treated confidentially. If a special accommodation is needed or if employees have a disability and do not wish to indicate this on the form, they may contact Human Resources.

Refusal to provide the information will not subject the applicant or employee to any adverse treatment, and the information will only be used in accordance with the regulations implementing the Rehabilitation Act.

The following guidelines are intended to assist Univer sity supervisors and staff in working with employees and applicants with disabilities.

1. No qualified individual with a disability shall on the basis of the disability be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination in any aspect of the employment process at Purdue Calumet.

2. Purdue Calumet takes affirmative action to employ and advance in employment qualified individuals with disabilities.

3. Purdue makes reasonable accommodations to known phys ical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless the accommodation or request for services would impose an undue hardship on the employing unit.

4. Purdue Calumet does not knowingly participate in a contractual or other relationship that has the effect of subjecting applicants or employees with disabilities to discrimination.

5. Purdue Calumet does not knowingly use employment selection criteria that is discriminating. Arrangements may be made for alternative testing or selection criteria that impair sensory, manual, or speaking skills for people with disabilities.

6. Information concerning a disability, medical condition, or medical history may be necessary to determine whether the disability is job related. Any employee or applicant to whom such an inquiry is directed shall be provided the opportunity to explain why the disability either is not related to the requirements of the job or what reasonable accommodations can be made.

7. Alcoholism, drug addiction, and aids are recognized as disabilities as defined in the Americans with Disabilities Act. However, the term "qualified individual with a disability" shall not include any employee or applicant who is currently engaging in the illegal use of drugs.

All employees in similar situations are be evaluated with the same criteria. In considering employees with disabilities, evaluations are made in terms of actual job requirements and possible accommodations that will enable them to do the job. Evaluations may involve matching their combinations of strengths and weaknesses to do the job.

The Affirmative Action Office and Human Resources may assist employees with disabilities in arranging for accommodations and locating adaptive equipment. Employees or Supervisors may contact the Affirmative Action Office or Human Resources for information or assistance concerning accommodations. A job accommodation could include priority snow removal, adapted transportation or equipment, construction to eliminate architectural barriers, amplified telephone receivers, (TDD's), print enlargers, or modified computer software. This list is not meant to be exhaustive, but instead to provide a sample of what accommodations may be performed. Often times accommodations need to be handled on a case-by-case basis.

Reasonable accommodations must be made unless Purdue Calumet can demonstrate that such an accommodation would impose an undue hardship. In determining the extent of the obligation to the accommodation, business necessity and financial cost and expenses are considered.

A review of all physical and mental job qualification requirements is performed by the Human Resources as job descriptions are reviewed and/or updated periodically. This ensures that qualification requirements do not screen out qualified individuals with disabilities, that job requirements are job related, and that they are consistent with business necessity and the safe performance of the job.

Each department at Purdue Calumet will consider an applicant in terms of actual job requirements necessary for performing the job competently. Hiring decisions may not deny the opportunity for employment to an otherwise qualified individual with a disability because of the physical or mental impairment. Not employing an individual with a disability who is unqualified or who cannot be provided with a reasonable accommodation is not discrimination. All applicants are given the opportunity to request special services, assistance, or equipment in order to perform a job or apply for a position.

Pre-employment inquiries are permitted only if the basis for questioning is job related. Medical examinations are not permitted until after an individual has been offered a position, and only if such examination is directly related to the position and if all similar positions require a physical.

The University may require the applicant to provide medical documentation of a disability if an employee is claiming a disability or requesting an accommodation. Determination of a disability shall be kept confidentially as is other medical data and shall not be used to exclude the individual.

Physical or mental requirements for all vacancies shall be reviewed prior to the position's announcement to avoid discrimination against individuals with disabilities. All major physical and mental job related requirements shall be written into the job description.

The Affirmative Action Office or Human Resources may be consulted to assist in accommodations being considered by the unit, or department involved. This may involve analyzing and restructuring jobs for the individual employee or applicant with a disability.

Information concerning a disability or medical history of an employee shall be treated as medical records and are retained through the use of forms accorded confidentiality as medical records. Exceptions may include the following:

1. Supervisors may be informed regarding restrictions on the work or duties of employees with disabilities and regarding accommodations.

2. First aid and safety personnel may be informed, where and to the extent appropriate, if the condition might require emergency treatment.

3. Government officials investigating compliance with the Act shall be informed.

If an employee claims to have a disability, but there is reasonable cause to doubt the employee, medical documentation can be required. Any information obtained from such medical inquiries must be used in accordance with job related standards.

An employee may allege discrimination on the basis of a disability in violation of the University policy on non-discrimination. Practices and procedures outlined in Equal Opportunity Memorandum 3, "Nondiscrimination on the Basis of Handicap," and Equal Opportunity Memorandum 7, "Affirmative Action in Employment for the Handicapped," applies to complaints alleging discrimination on the basis of a disability. Copies of these memorandums may be obtained by requesting them from the Affirmative Action Office.

Attempts to resolve disputes should first be done internally within the University guidelines. The employee and/or the employer should consult the Affirmative Action Office and/or Humane Resources in order to resolve a discrimination complaint as soon as possible. The internal review process followed by the Affirmative Action Office in matters concerning employees with disabilities will be consistent with other issues of discrimination.

If a complaint isn't resolved internally, an employee may file a complaint with the Director of the Office of Federal Contract Compliance Programs, or the Equal Employment Opportunity Commission. The complaint must be filed within 180 days from the date of the alleged violation, unless the time limit is extended by the Director for good cause.

This document is published to comply with the regulations section 402 of the Vietnam Veterans' Readjustment Assistance Act of 1974, 38 U. S. C. 2012. This Affirmative Action Plan for veterans with disabilities and veterans of the Vietnam era is reviewed and updated each year by the Affirmative Action Office in conjunction with other affirmative action plans.

Purdue Calumet is obligated, as a government contractor and recipient of federal funds, under Section 402 of the Veterans' Readjustment Assistance Act of 1974, to take affirmative action to employ and advance in employment disabled veterans and veterans of the Vietnam era. The University will treat veterans with disabilities and veterans of the Vietnam era without discrimination based on their physical or mental disability in all employment practices such as recruitment, hiring, promotion, granting of tenure, compensation, employee benefits, discipline, termination, University sponsored training, selection for training, education tuition assistance, transfer, demotion, layoff, return from layoff, recreation programs, and all other conditions, privileges of employment, or other employment benefits.

The following definitions from 41 CFR 61-250.2 are provided for a better understanding of the law and the University's commitment.

"Special disabled veteran" means (i) a veteran 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 Veterans Administration for a disability (A) rated at 30 percent or more, (B) rated at 10 or 20 percent in the case of a veteran who has been determined under section 1506 of Title 38, U.S.C., to have a serious employment handicap; or (ii) A person who was discharge or released from active duty because of service-connected disability.

"Veteran of the Vietnam era" means a veteran, any part of whose active military, naval, or air service was during the period August 5, 1964, through May 7, 1975, who - (i) Served on active duty for a period of more than 180 days and was discharged or released therefrom with other than a dishonorable discharge, or (ii) Was discharged or released from active duty because of a service-connected disability.

No veteran may be considered to be a veteran of the Vietnam era under this paragraph after December 31, 1994.

The responsibility for the University's Affirmative Action Programs, including the Vietnam Era Veterans Readjustment Assistance Act of 1974, 38 U. S. C. 2012 is under the Chancellor, Dr. James Yackel. In turn, operational responsibility is assigned to the Affirmative Action Officer, Ralph Ocon.

Each publication produced by the University contains a non-discrimination statement. Advertisements for faculty or non-faculty positions contain the statement "An Equal Opportunity/Affirmative Action Employer." The Affirmative Action Office checks for the statement in faculty advertisements and Human Resources checks non-faculty advertisements. Publications pertaining to special events, programs, and activities contain the statement "Equal Opportunity/Equal Access University." For further description of responsibilities regarding publicat ion, see Part One, section VI, E and F of the Affirmative Action Plan.

The Affirmative Action Office and Human Resources integrates information on Vietnam Era Veterans and their affirmative action rights through regular training programs.

The posters required by federal and state law, which provide the names of federal agencies to contact in regard to questions or complaints are posted in conspicuous areas within each building.

The Affirmative Action Plan under the Vietnam Era Veterans Readjustment Assistance Act of 1974, 38 U. S. C. 2012 is available for inspection Monday through Friday between 8:30 a.m. to 4:30 p.m. in the Affirmative Action Office, Lawshe Hall, Hammond, IN 46323.

Each March, an Employee Information Review Form is distributed to provide the opportunity for employees to voluntarily review and update their personnel records. Information pertaining to a veteran with a disability or a Vietnam Era Veteran is treated confidentially and if a special accommodation is needed the individual may contact the Affirmative Action Office Human Resources.

In determining the qualifications of a covered veteran, the University considers only that portion of the military record, including discharge papers, relevant to the specific job qualifications for which the veteran is being considered.

As a contractor with the federal government, Purdue Calumet must report at least annually the numbers of special veterans with disabilities and veterans of the Vietnam-era in their workforce by job category and hiring location and the total number of employees and the number of special veterans with disabilities and veterans of the Vietnam-era hired during the reporting period.

The report, referred to as the "Vets 100 Report," is produced and submitted by the Affirmative Action Office in West Lafayette to the Office of Federal Contract and Compliance Programs. This report is available in the Affirmative Action Office during regular office hours.

Job-related qualifications are specified in job descriptions, vacancy announcements, and selection criteria. Human Resources is responsible for updating the descriptions and ensuring that they are non-discriminating.

In determining the qualification of a covered veteran, the University may consider only that portion of the military record, including discharge papers, relevant to the specific job qualifications for which the veteran is being considered.

Human Resources also maintains an Applicant Flow Register which tracks all applicants referred to job openings.

Where a covered veteran is hired, promoted, or trained, and a special accommodation is needed, the personnel file of the covered veteran should contain a description of the accommodation.

The position vacancy notices for clerical/service staff and administrative professional staff is delivered to the Indiana Department of Employment and Training Services by Human Resources Services. Likewise, the Affirmative Action Office disseminates faculty vacancy notices to the same division of Indiana state government.

The Human Resources reviews position descriptions and qualifications for non-academic staff. Each academic dean and department head reviews, in consultation with the faculty, qualifications, and specifications for each academic vacancy. At the present time physical and mental qualifications are included in the review of position descriptions and selection criteria.

Purdue Calumet will consider an applicant in terms of actual job requirements necessary for performing the job competently. Supervisors' hiring decisions may not deny the opportunity for employment to an otherwise qualified individual with a disability because of the physical or mental impairment. Not employing an individual with a disability who is unqualified or who cannot be provided with a reasonable accommodation is not discrimination. The hiring supervisor must give applicants the opportunity to request special services, assistance, or equipment in order to perform a job or apply for a position. Pre-employment inquiries are permitted only if the basis for questioning is job related. Medical examinations are not permitted until after an individual has been offered a position, and only if such examination is directly related to the position and if all similar positions require a physical.

The documentation provisions, policy, and procedures applicable to people with disabilities cited in Part Two, apply equally to veterans with disabilities.

Information concerning a disability or medical history of an employee may be required and are treated as medical records and are retained through the use of forms accorded confidentiality as medical records. Exceptions may include the following:

1. Supervisors may be informed regarding restrictions on the work or duties of employees with disabilities and regarding accommodations.

2. First aid and safety personnel may be informed, where and to the extent appropriate, if the condition might require emergency treatment.

3. Government officials investigating compliance with the Act shall be informed.

The University may require the applicant to provide medical documentation of a disability if an employee is claiming a disability for which he or she is requesting an accommodation. Determination of a disability shall be kept confidentially as is other medical data and shall not be used to exclude the individual.

The University's discrimination policies and procedures which refer to the Affirmative Action Plan under the Rehabilitation Act of 1973 applies equally to veterans.

An applicant or an employee may allege discrimination on the basis of a disability or veteran status.

Attempts to resolve disputes should first be done internally within the University guidelines. The employee and the supervisor should consult the Affirmative Action Office and/or Human Resources in order to resolve a discrimination complaint as soon as possible. The internal review process followed by the Affirmative Action Office in matters concerning veterans with disabilities and veterans of the Vietnam era will be consistent with other issues of discrimination.

For dispute resolution, staff may refer to Executive Memorandum B-29, "Equal Employment Opportunity Policy - Complaint Procedure." Faculty may follow the procedures outlined in Executive Memorandum C-19, "Grievance Procedures for Academic Personnel," Administrative/Professional staff may refer to Executive Memorandum B-37, and Clerical/Service staff may refer to Business Service Memorandum 137. Copies of these executive memorandums are available in the Affirmative Action Office.

If a complaint is not resolved internally, an employee may file a complaint with the Director of the Office of Federal Contract Compliance Programs, or the Equal Employment Opportunity Commission. The complaint must be filed within 180 days from the date of the alleged violation, unless the time limit is extended by that director for good cause.