The Affirmative Action Committee is selected by and reports to the President of St. Ambrose University.

The Affirmative Action Committee's purpose is to (1) review and evaluate the Affirmative Action Plan at least once annually; (2) recommend such changes in the plan which it deems appropriate; and (3) hear grievances arising under such plan whenever necessary.

Equal Opportunity / Affirmative Action Plan

ST. AMBROSE UNIVERSITY AFFIRMATIVE ACTION PLAN
POLICY STATEMENT
It is the policy of the University to provide equal opportunity in all terms and conditions of employment and education for all faculty, staff and students. The intent of this policy is to prohibit discrimination (including sexual harassment) and to promote the full realization of equal employment opportunity through a continuing affirmative program in all faculty, staff and student aspects of the University.

The University will provide equal opportunities for all qualified individuals and will promote the full realization of equal opportunity through positive programs. This policy of equal employment opportunity applies to all individuals in every aspect of education, employment policy and practice.

Further, the University is committed to a comprehensive program of affirmative action to insure access, equity, and fairness in educational programs, related activities and employment for minorities, women, handicapped persons, disabled veterans and persons with veteran status.

The University is an Affirmative Action Equal Opportunity Employer and provides that employment, salaries and access to education should not be restricted because of race, color, religion, age, sex, national origin, handicap or veteran status.

A. PROGRAM ADMINISTRATION
1. The Personnel Director shall act as the special assistant to the President to serve as the Affirmative Action Officer and ex officio member of the Affirmative Action Committee.
2. The Affirmative Action Committee shall (1) review and evaluate the plan at least once annually; (2) shall recommend such changes in the plan which it deems appropriate; and (3) shall hear grievances arising under such plan whenever necessary.
3. The Affirmative Action Committee will report either directly to the President or throught the Affirmative Action Officer its findings and recommendations.
4. Recommendations concerning the Affirmative Action Plan will be made to the President by the Affirmative Action Committee after appropriate consultation.
5. The final responsibility for the administration of the Affirmative Action Plan rests with the President of the University. He has primary responsibility for filling the office positions directly reporting to him and the responsibility to ensure that, at all levels, necessary action as outlined here is taken to carry out the University Affirmative Action Plan.

B. OBJECTIVES
The objectives of the St. Ambrose University Affirmative Action Plan are to further develop and maintain truly equal employment opportunity for all personnel and to eliminate as much as is possible under-representation in employment because of race, creed, color, religion, national origin, sex, age, handicap or veteran status. The University additionally commits itself to develop a work force which reflects equitable distribution of minority group members and women at all levels of employment and throughout all departments of the University. St. Ambrose specifically undertakes a program of affirmative action to achieve the following purposes:

1. Determination of the extent to which minorities and women are under-utilized in major categories;
2. Identification and elimination of the specific causes of such under-utilization;
3. Identification and elimination of employment practices which have been adverse on minorities, women and others protected by law and those relating to job performance that have not been clearly established;
4. Replacement of such practice by others which are based on merit and valid job qualifications;
5. Development, through special recruitment efforts and other measures, of applicant pools in which qualified minorities and women are represented in proportions sufficient to help reduce their under-utilization, where such has occurred;
6. Development, through special recruitment efforts and other measures, of applicant pools in which handicapped persons and veterans are represented equitably;
7. Projection of goals and timetables which will estimate the representation of minorities and women which is likely to result from the operation of this affirmative action plan;
8. Establishment of organizational structures and monitoring systems which will assure effective operation of the affirmative action program, achievement of its goals, and modification of the plan as appropriate to those ends.

C. DISSEMINATION OF POLICY
Inasmuch as an uncommunicated policy will be of little value, St. Ambrose University will make a determined effort to communicate such policy. Procedures for communication of the Affirmative Action Policy of the University will include the following:

1. Make the Affirmative Action Plan available to all employees;
2. Develop contacts with public and private agencies involved in affirmative action and equal employment opportunity;
3. Send letters to employment agencies and other agencies involved in affirmative action/equal employment opportunity placement, briefly outlining the affirmative action policy of the University;
4. Publicize the policy in the official University publication and in other University and community news media;
5. Conduct special meetings with supervisory personnel at all levels to explain the intent of the policy and individual responsibility for effective implementation;\
6. Schedule special meetings with all other non-supervisory employees to discuss the affirmative action policy and explain individual employee responsibilities;
7. Discuss the affirmative action policy thoroughly in both employee orientation and appropriate employee training programs.

D. AUDIT OF EMPLOYMENT PRACTICES
St. Ambrose University will review all its employment practices in order to identify and eliminate any practices which may have contributed to under-utilization of minorities and women, and which are necessary to the operation of the institution and do not bear a direct relationship to the jobs for which they are used as screening devices.

Practices to be reviewed, initially and periodically, will include, but not be limited to, the following:

1. The initial application and interview procedure;
2. The content of job descriptions, in terms of their possible adverse effect on minorities or women;
3. All pre-employment tests - (only manipulative skills tests are administered);
4. All job qualifications, including requirements for experience and education;
5. All criteria, such as arrest records, marital status, garnishments and others, which may be used as disqualifying factors for employment;
6. All advertising procedures; all programs, such as distribution of benefits and others, which bear upon opportunities for advancement within the institution.

Such employment practices will be reviewed by the Affirmative Action Officer in consultation with the President, according to the provisions of this Plan. The results of each such review, including any recommendations for change, will be stated in writing to the appropriate Officer of the University.

E. RECRUITMENT
St. Ambrose University undertakes a program of recruitment for minority group members and women in all job categories and academic programs in which they have been under-utilized.

In all positions and programs, regardless of whether or not such under-utilization currently exists, the institution will pursue a program of open recruitment to avoid the possible discriminatory effects of informal job networks and similar systems.

Procedures for recruitment of employees will include the following specific actions:

1. Identify departments where few or no women or minority group members are employed and make special efforts to fill vacancies in these departments with qualified women or minority group members;
2. Develop contacts with agencies involved in placing minority group applicants and use where appropriate these agencies in recruiting qualified applicants;
3. Advertise in minority group newspapers and other publications where applicable;
4. Exert extra effort to talk to minority group members and women when recruiting for faculty through personal contacts, professional contacts, professional meetings, University recruiting, and so on;
5. The phrase "affirmative action/equal opportunity employer" or "AA/EEO" will be used in recruiting publications, including employment advertising. Ads will be designed to indicate that women will be considered equally with men for jobs, unless sex is a "bona fide occupational qualification;"
6. Particularly in the case of academic personnel, effective channels of recruitment include the following:

a. Advertisements in appropriate professional journals and job registries;
b. Unsolicited applications or inquiries;
c. Women teaching at predominantly women's colleges, minorities teaching at predominantly minority colleges;
d. Minorities or women professionally engaged in non-academic positions, such as industry, government, law firms, hospitals;
e. Professional women and minorities working at independent research institutions and libraries;
f. Professional minorities and women who have received significant grants or professional recognition;
g. Women and minorities already at the institution and elsewhere working in research or other capacities not on the academic ladder;
h. Minority and women graduate degree recipients, from the University itself, and from other institutions, who are not presently using their professional training
i. Women and minorities presently candidates for graduate degrees at the institution and elsewhere who show promise of outstanding achievement;
j. Minorities and women listed in relevant professional files, registers and data banks, including those which have made a conscientious effort to locate women and minority persons.

7. In order to facilitate recruitment, a central file shall be developed and made available to the search committee(s), containing materials, data and examples of procedures which may be considered for use to rectify under-utilization of women and minority persons.
8. St. Ambrose University is committed to the recruitment of qualified minority students. Scholarship programs have been established specific to identification and recruitment of minority students. Information on these programs is available from the St. Ambrose Admissions Office. The University also has a part-time Minority Counselor to work specifically with our minority students to respond to their concerns and needs. This individual helps in both the areas of minority student recruitment and retention.

F. SELECTION, PROMOTION AND OTHER EMPLOYMENT RELATED PRACTICES
The St. Ambrose University selection policy recognizes that a widely communicated Affirmative Action Plan coordinated with intensive recruitment will be inadequate unless followed by appropriate selection and other employment related practices.

Accordingly, procedures for selection of employees will include the following:

1. Review current selection criteria to ensure they are non-discriminatory and are designed to fill vacancies with best qualified personnel without regard to race, color, religion, national origin, sex, age, handicap and veterans. Examples of pre-employment inquiries which may be forms of either overt or covert discrimination include all such items which are listed in Appendix I: Pre-Employment Inquiry Guide.
2. All non-faculty job openings will be referred to the Personnel Director and all faculty openings will be referred to the Provost to be handled jointly with the Personnel Director.

Their responsibilities include that of ensuring:

a. that all applicants are uniformly screened so that equal opportunity in employment can be assured; and
b. that heads of departments involved in the selection process are aware of their responsibilities in equal employment opportunity and affirmative action, and that such awareness is reflected in written job descriptions, including criteria, and in selection interviewing.

3. Before any applicant for employment is hired, the Affirmative Action Officer will:

a. review the procedures followed with respect to recruitment for the position in question and the selection of the individual being recommended for employment;
b. certify in writing that so far as the Affirmative Action Officer has been able to determine, the procedures followed with respect to recruitment and selection comply with the provisions of the Affirmative Action Plan, as well as with its spirit and intent. Those involved in the recruitment and selection process pertaining to a position to be filled should keep the Affirmative Action Officer currently informed of the procedures being followed;
c. indicate why the candidate selected for the position is the best qualified of the applicants or, in the alternative, show why the candidates not selected are less qualified for the position than the candidate selected.

4. Procedures for promotion of employees will include the following:

a. review "promotion from within" policy to ensure personnel are considered for vacancies based on performance and potential without regard to race, color, religion, sex and so on. When the pool of promotables is not representative of available women and minorities, the University has the responsibility to (1) expand the pool to include such persons, or (2) show "business necessity" and that there is no alternative criteria which would produce a better result.
b. provide counseling and guidance for both promotables and supervisors wherever possible.

Job Classification
The University will review job classifications and position descriptions for all staff positions and make sure that all are classified without regard to race, color, religion, national origin, sex, age handicap and veteran status.

Salary Administration
The University will take whatever steps are necessary to review all employee positions to ensure rates being paid are commensurate with other comparable positions held within the institution. The University will begin such review by starting with those positions held by minority groups and female employees.

G. RECORDS AND REPORTS
The maintenance of records is critical with regard to the appropriate evaluative analysis. The University, accordingly, will take the action which follows:

1. Records and reports will be maintained and prepared in strict compliance with the appropriate federal documents;
2. Currently, the primary responsibility for all recruitment is under the purview of the Personnel Director. The actual interviewing and selection process is handled by the Provost in the case of faculty, and the individual department heads in the case of non-faculty positions;
3. Therefore, on or before January 1 of each year, the Personnel Director and the Provost will submit a written report setting forth:

a. familiarity with the Affirmative Action Plan;
b. assessment of under-utilization of women and minorities in the areas for which the reporting individual has responsibility;
c. goals and timetables for rectifying such under-utilization;
d. an evaluation of the Affirmative Action Plan as it applies to the reporting individual's area of responsibility;
e. suggestions for remedying any noted weaknesses in the Affirmative Action Plan.

Detailed reports and analysis of the number, salary record, and advancement record of minority group employees will be made by the University Affirmative Action Officer on an annual basis to determine the progress of the University in its Affirmative Action Plan, its strengths and weaknesses, and the action needed for more effective implementation.

Specifically these reports will include a:

a. comparative study of salaries, fringe benefits, and leave and vacation benefits
paid to men, women and minority faculty;
b. comparison of the percent of increase in salaries awarded to men, women and minority faculty for the most recent academic year;
c. study of salaries, fringe benefits, and vacation benefits paid to men, women and minority staff and professional staff;
d. comparison of the percent of increase in salaries awarded to men, women and minority staff in professional staff positions.

H. NEPOTISM POLICY
St. Ambrose University will not prohibit the employment of spouses or other relatives in the same department or administrative unit, provided that neither spouse nor other relative participates in making recommendations affecting the appointment, retention, tenure, work assignments, promotion, demotion, or salary of the other spouse or relative, and provided that no preferential policy toward spouses or relatives shall be used to deny equal opportunity.

I. EQUAL PAY/BENEFITS
St. Ambrose University is committed to the principle and practice of equal pay/benefits for equal work, as required by the Equal Pay Act of 1963, Title VII of the Civil Rights Act of 1964, as amended, and other laws.

In no case will St. Ambrose pay or give benefits to similarly qualified individuals performing the same work under comparable conditions of job tenure, different wages or salaries on the basis of sex, minority status or any other factor not permitted by law.

To assure that any unjustified differentials which may exist are corrected, St. Ambrose will take the following actions:

1. The Personnel Director under procedures developed in conformity with the Affirmative Action Plan will review the pay/benefits of employees in all major support categories;
2. Any significant disparities found to exist by sex or minority status will be brought to the attention of the responsible department or unit head, who will be requested to provide documented justification for the differentials, consistent with law;
3. In the absence of such documented justification, the University will make salary/benefit adjustments necessary to achieve compliance with the principle of equal pay for equal work. In no case will such compliance be achieved through the reduction of any employee's salary or benefits;
4. Any employee of St. Ambrose University who believes that because of his or her race, color, religion, sex, national origin, age, or handicap, he or she is being provided with pay or benefits less than other similarly qualified persons performing the same work under comparable conditions of job tenure, may file a grievance under the University's grievance procedures, in the same manner as any other complaint regarding equal employment opportunity may be filed.

J. LEAVE POLICIES
All leave policies of St. Ambrose University will be formulated and administered without discrimination on the basis of sex or any other prohibited ground.

Extended leave of absence without pay, i.e., long-term military leave, family leave, etc., will be granted without discrimination because of sex or any other prohibited ground.

K. SEXUAL HARASSMENT
St. Ambrose University reaffirms the principle that its students, faculty, and staff have a right to be free from six discrimination in any form, including sexual harassment by any member of the academic community.

Sexual harassment is defined as an attempt to coerce an unwilling person into a sexual relationship, or to subject a person to unwanted sexual attention, or to punish a refusal to comply, or to create a sexually intimidating, hostile, or offensive working or educational environment. Sexual harassment is understood to include a wide range of behaviors, from the actual coercing of sexual relations to the unwelcomed emphasizing of sexual identity. This definition will be interpreted and applied consistent with accepted standards of mature behavior, academic freedom, and freedom of expression.

Sexual harassment in any situation is reprehensible; it is particularly damaging when it exploits the educational dependence and trust between students and faculty. When the authority and power inherent in faculty relationships to students, whether overtly, implicitly or through misinterpretation, is abused in this way, there is potentially great damage to individual students, to the persons complained of, and to the educational climate of the University. While a particular interaction must be offensive and unconsented to be defined as harassment, faculty members and other individuals in positions of authority should be sensitive to the questions about mutuality of consent that may be raised and to the conflicts of interest that are inherent in personal relationships where professional and educational relationships are also involved.

Individuals who believe they have been sexually harassed may obtain redress through the established procedures of the University. Complaints about sexual harassment may be filed in one of the following offices: Provost's Office; Personnel Office; and, Dean of Student's Office. All complaints will be responded to promptly and equitably. The right to confidentiality of all members of the academic community will be respected in these procedures, insofar as possible. This policy explicitly prohibits retaliation against individuals for bringing complaints of sexual harassment. Formal procedures will not be initiated without a written, signed complaint. An individual found to be guilty of sexual harassment is subject to disciplinary action for violations of this policy, consistent with existing procedures.

Any individual who feels that a sexual harassment complaint did not receive prompt and equitable response should contact the Office of the President.

L. GOALS AND TIMETABLES
St. Ambrose University will establish, separately for minorities and women, goals and timetables relating to their employment in each major job category in which they have been found to be under-utilized by the University.

The University's goals and timetables will not be developed or administered as inflexible quotas which must be met, nor will they be administered in a manner which discriminates in the hiring, appointment, promotion or granting of tenure to any individual on grounds of race, color, religion, age, sex, national origin, handicap or veteran status. Goals and timetables will be projected as appropriate for women and racial minorities.

M. EXTERNAL RELATIONSHIPS
St. Ambrose University in order to achieve the goals of equal employment opportunity and equal educational opportunity as spelled out previously, takes the following action:

All recruiters who recruit with the University will be informed of the University's non-discrimination policy and will be asked to provide affirmative information with regard to their policy of non-discrimination in employment practices prior to the award or renewal of such contract. If such a showing cannot be made, the University will not further pursue the contact until the recruiter is in compliance with the University's policy of non-discrimination.

N. STAFF ORIENTATION IN EEO
In addition to receiving copies of this plan and its guidelines for implementation, as provided for in Section C, responsible supervisory personnel will be given special orientation sessions regarding the provisions of the Plan and of equal employment opportunity law generally.

O. GRIEVANCE PROCEDURES
Grievance procedures are promulgated in the hope that their accessibility, simplicity, speed and high standards of fairness will encourage employees and students to choose the internal forum over an external one in seeking redress of perceived injustices.

These grievance procedures in their entirety will be found in the following handbooks:

1. Faculty Handbook (Section 2.2.3)
2. Personnel Manual for Administrative Staff (Section 34.000)
3. Student Handbook (General Information Section, Page 6)

Coverage. These procedures apply to any grievance which may arise in matters of general personnel administration and matters involving rights provided for under this Affirmative Action Plan which directly affect the personal interests and well-being of any individual employee or student.

Grievances which do not directly involve the personal interests and well-being of an individual employee or student and which are not otherwise covered by these procedures, should be referred to the Human Resources Director, Provost, or Dean of Students, whichever is appropriate.

Eligibility. Any employee or student who believes that he or she has been done an injustice through the action of another employee, supervisor, teacher, student or other person acting for the University may bring a grievance under these procedures.

Interpretation of Coverage. Where a dispute exists as to whether a particular matter is subject to coverage by these grievance procedures, the Affirmative Action Officer will make an initial recommendation to the President on such matters of coverage. The University President, however, reserves the right to make the final judgment on that question.

In making that final judgment, the President, just as the Affirmative Action Officer will interpret the coverage of these procedures liberally. He or she will deny application of the procedures only where the matter in question clearly concerns issues of broad policy in which the complaining party has no direct interest, where the President has good reason to believe that a grievance has been brought in bad faith for political or similarly inappropriate reasons, or in other circumstances in which use of these procedures would clearly endanger their effectiveness as an instrument for the redress of grievance.

Retaliation. Any retaliatory action of any kind taken by any employee or student of the University against any other employee or student of the University as a result of that person's seeking redress under these procedures, cooperating in an investigation, or other participation in any proceeding under these procedures is prohibited and shall be regarded as a separate and distinct grievable matter under these procedures.

P. EFFECTIVE DATE OF PLAN
St. Ambrose University will use diligence and good faith to effectuate the outlined plan. As a result, the University's Affirmative Action Plan shall take effect as soon as practicable and no later than July 1, 1989.

APPENDIX I
PRE-EMPLOYMENT INQUIRY GUIDE

Subject Permissible Inquiries Inquiries that must be avoided

Any inquiry should be avoided which, although not specifically listed among the above, is designed to elicit information as to race, color, ancestry, age, sex, religion, handicap, or arrest and court record unless based upon a bona fide occupational qualification.

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