if(currentUrl.indexOf("/about-shrm/pages/shrm-china.aspx") > -1) { Official websites use .gov This allows you to tell the companys side of the situation at hand. EEOC has implemented nationwide procedures that provide for the release of Respondent position statements and non-confidential attachments to a Charging Party or her representative upon request during the investigation of her charge of discrimination. Creating a Legally Sound Remote Work Policy: The 5 Biggest Pitfalls to Avoid, FMLA Cheat Sheet: A Handy At-A-Glance Guide, Gender Identity, Affirmation, & Transition: The Ultimate Guide for HR, Why Good People Jump Ship And What You Can Do To Keep Them, 15 Practical Tools To Help New Employees Succeed. If the EEOC finds reasonable cause to believe that discrimination occurred, the parties receive a Letter of Determination. This prevents any interruption of content access. LockA locked padlock You will receive a link to create a new password via email. Compare all factual representations made in the position statement to all documentation. -ulR;&{+ ( Generally, the position statement should include the follow components in the following order: Start strong-with a firm denial and a brief summary of the company's position. If during the course of the investigation, EEOC determines that it needs additional evidence from the Respondent, including information to address the Charging Party's rebuttal to the position statement, the Investigator will contact the Respondent. Need help with a specific HR issue like coronavirus or FLSA? When someone files a discrimination complaint against your company with the Equal Employment Opportunity Commission (EEOC), federal law provides you with the right to respond with an EEOC position statement. For Deaf/Hard of Hearing callers: However, the EEOC may conduct interviews of non-management personnel without the presence of company representation. Any reference to charges filed against the employer by other charging parties. If the charge evolves into a lawsuit, the position statement and any supporting documentation can be admitted as evidence. The procedures will also provide EEOC with better information from the parties to strengthen our investigations. Sensitive medical information (except for the Charging Party's medical info). EEOC also requests that you submit all documentary evidence you believe is responsive to the allegations of the charge. You know that scientist in the action movie who has all the right answers if only the government would just pay attention? Ready, set, grow:The building blocks for high-impact talent mobility will help you better understand your employees expectations around internal development and what your leaders must do to succeed. The assistant superintendent subsequently shared the information with the superintendent, who then called the supervisor at the employees part-time job and confirmed that she had worked the previous day. A position statement focused on the allegations of the charge helps EEOC accelerate the investigation and tailor its requests for additional information. Further, deposition testimony from Shenandoah Valley management officials conflicted with the position statement submitted long before the emplyee had filed the lawsuit. Employers relying on confidential information in responding to a Charge should provide this information in separate, clearly-labeled attachments. So, how do you draft a Position Statement that makes the EEOC like, and the Charging Party like? Responding to a charge of discrimination usually involves two components: preparation of an employer's "position statement;" and The Position Statement where you plant your flag and defend your hill. With The EEOC may request interviews of these individuals during their investigation. 8/x),Q}) 8 &bm)E8J_\4J,)d0W/O:]u:tyTd:ahX,S2F-!\;] For example, saying an employee was laid off for business reasons wont cut it. Now that you have completed your EEOC position statement and filed it pursuant to the Digital Charge System, you may wonder what to do next. Conciliation is a voluntary process, and both parties must agree to the resolution. The contact form sends information by non-encrypted email, which is not secure. As always, should you have any questions regarding these new procedures or need assistance responding to an EEOC Charge of Discrimination, please contact Stacie Caraway or any member of our Labor & Employment Law Practice Group. In that case, managers at Shenandoah Valley, a juvenile detention home, fired an employee for allegedly falsifying a sick leave report. Its essential to make sure any reasons given for an employment action are well-documented, agreed upon by all decision-makers and carefully articulated. 3Vwuq/eAo\_?w`9M.,p4?l>lw;xG3Pd43pp EEOC will provide the Respondent's position statement and non-confidential attachments to Charging Parties upon request and provide them an opportunity to respond within 20 days. Select the "Position Statement" Document Type and click the Save Upload button to send the Position Statement and attachments to EEOC. $("span.current-site").html("SHRM China "); What if Respondent needs additional time to submit its position statement? Supporting documentation should include the following: In many instances, an EEOC discrimination charge may eventually result in litigation. Accordingly, the court denied Shenandoah Valleys request for summary judgment, permitting the claim to proceed to trial. A staffing or organizational chart is also useful in helping to focus the investigation. Identify any individuals other than the Charging Party who have been similarly affected by these practices, policies or procedures; describe the circumstances in which the practices, policies, or procedures have been applied. } var temp_style = document.createElement('style'); Webmay have that relate to your case. Members can get help with HR questions via phone, chat or email. Your statement should directly respond to each claim made against your company and should include your version of the facts. My question to you would be why in the world are you not having a lawyer prepare your statement for you? Would you perform surgery on yourself? In Your session has expired. Submitting a request for extension of time does not automatically extend the deadline for providing the position statement. $(document).ready(function () { If youve everhad to addressa Charging PartysEEOC Charge of Discrimination, you know that drafting a good Position Statement, in which the specific claims of discrimination are addressed and supported with documents and facts is hella-key. Yes. Keep the following points in mind as you prepare the response to the charge: An effective position statement is clear, concise, complete and responsive. We possess extensive experience in administrative proceedings throughout the United States. info@eeoc.gov An employer shouldnt takerestraint inits position statement too far. For example, the EEOC requires proof of due diligence and a good faith effort to supply all required information. Practical HR Tips, News & Advice. This new procedure is designed to facilitate the EEOC obtaining additional responsive information from the Charging Party while the Charge is still pending. You also receive a copy of this notice. Find the latest news and members-only resources that can help employers navigate in an uncertain economy. [SHRM members-only toolkit: Avoiding Adverse Impact in Employment Practices]. If Respondent believes it requires additional time to respond, it must, at the earliest possible time in advance of the due date, make a written request for extension, explain why an extension is necessary, and specify the amount of additional time needed to reply. Again, remind them that they may be called to testify as to its factual accuracy. $("span.current-site").html("SHRM China "); Please purchase a SHRM membership before saving bookmarks. I also help clients litigate disputes involving restrictive covenants such as non-competition and non-solicitation agreements, as well as conflicts over use of trade secrets and other confidential information. If you do not submit a position statement or respond to EEOC's requests for information, the EEOC may proceed directly to a determination on the merits of the charge based on the information at its disposal or subpoena specific information related to the allegations in the charge. Please note that all such forms and policies should be reviewed by your legal counsel for compliance with applicable law, and should be modified to suit your organizations culture, industry, and practices. Get access to 100's of HR resources in HRM INSIDER. A .gov website belongs to an official government organization in the United States. A representative may be present for any interviews with management personnel. Testimony: Testimony is simply a statement taken from someone who would be in a position to have firsthand knowledge about what happened to you. The charging party was absent from work for three days and Employer position regarding each alleged discriminatory act; Company policies or practices regarding the discriminatory allegations; Identification of other parties affected by your company practices; Examples of similar situations where the implementation of company policies or practices did not result in similar allegations; Names of officials taking action related to the discriminatory allegation; A statement regarding the current status or resolution of the matter. Your card will not be charged at any point during your 21 day free trial The documentation you need to support your position regarding the EEOC claim may include the following: Providing evidence supporting your version of the facts as reflected in your EEOC position statement is a vital element of strengthening your position against such charges. A position statement that simply denies the allegations without providing your position or supporting information is not sufficient. Moreover, keep in mind that the EEOC may redact confidential information as necessary prior to releasing the information to a charging party. This new procedure is designed You should always consult with a licensed attorney about the specifics of your situation before taking any legal action. Sign up for a free HRMorning membership and get our newsletter! Build specialized knowledge and expand your influence by earning a SHRM Specialty Credential. From retail to healthcare, workers are subjected to discrimination and retaliation in the EEOC provides that the position statement should refer to, but not identify, confidential information. var currentUrl = window.location.href.toLowerCase(); This especially holds true now that the EEOC has announced new nationwide procedures that provide for the release of a companys Position Statement For Deaf/Hard of Hearing callers: Provide internal investigations of the alleged incidents or grievance hearing reports. Although no requirement exists for legal representation, failing to address all necessary elements in your EEOC position statement may result in an unfavorable investigation of the claim. But according to Stanley Pitts, an attorney with Honigman in Detroit, Being vague in your position statement will only make the investigator push and prolong her or his investigation.. It should clearly explain the Respondent's version of the facts and identify the specific documents and evidence supporting its position. After reviewing this rebuttal, the EEOC investigator may contact the employer to request additional information (or may employ one of the other "follow-up" methods described in the opening paragraph above). Yes, the Join/Renew Nowand let SHRM help you work smarter. EEOC may request specific documents, information or interviews from your organization concerning the charge. The notice includes information to the charging party that they possess the right to file a lawsuit in federal court within 90 days of receipt of the notice. 950 W. University Dr. Suite 300, Rochester, MI 48307. If you later move your flag to another hill (i.e., change your story), you may lose the war. Washington, DC 20507 SHRM Employment Law & Compliance Conference, Bad Position Statements Can Sink an Employers' Defense, OPM Moves Toward Continuous Screening of Federal Workforce, OSHA Given Authority to Grant Protection to Undocumented Workers. Confidential commercial or financial information. An organizational chart detailing company structure, Company policies related to the allegation, and. The Charging Party's response will not be provided to Respondent during the investigation. Please confirm that you want to proceed with deleting bookmark. " DHp,$DjGR-p While this process can be lengthy, its not nearly as time-consumingor costlyas the legal exposure you may face if you dont put in the effort upfront. For more about me, my practice, and my firm, this EEOC resource on Effective Position Statements.. Other EEOC attorneys may also review it. Build specialized knowledge and expand your influence by earning a SHRM Specialty Credential. 2 0 obj Be thorough from the start. Im a trial-tested, experienced litigator that has represented companies of all sizes in a veritable alphabet soup of employment law claims, such as the ADA, ADEA, CEPA, FMLA, FLSA, NJLAD, PHRA, Title VII, and USERRA. Contact our office today to discuss the allegations against your business and the next steps to take. <0j_y'gv\(gGrvn6[6i Unfortunately, review of your EEOC position statement may take some time. <>/Metadata 386 0 R/ViewerPreferences 387 0 R>> Have you ever faced an EEOC investigation? Therefore, retaining a qualified employment attorney to guide you through the process may limit delays and strengthen your case. Select the "Position Statement" Document Type and click the Save Upload button to send the Position Statement and attachments to EEOC. Bad Position Statements Can Sink an Employers' Defense A slipshod ~q The EEOC or state agency then notifies the employer of the charge and, in most cases, requests a formal, written response called a position statement.. Grants for extensions are uncommon, and sufficient grounds for the extension must exist. The EEOC also has released two sets of frequently-asked questions -- one geared toward employers and one toward Charging Parties -- relating to these new procedures on its website. Submitting a written request for extension of time which has not been granted does not relieve Respondent of complying with the deadline. During the investigation of a charge, EEOC may request that the Respondent employer submit a position statement and documents supporting its position. var currentLocation = getCookie("SHRM_Core_CurrentUser_LocationID"); Follow him Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. Share sensitive temp_style.textContent = '.ms-rtestate-field > p:first-child.is-empty.d-none, .ms-rtestate-field > .fltter .is-empty.d-none, .ZWSC-cleaned.is-empty.d-none {display:block !important;}'; This article was written by Miller Laws content team and reviewed for accuracy by attorney Marc Newman. Frequently Asked Questions, Commissioner Charges and Directed Investigations, Office of Civil Rights, Diversity and Inclusion, Management Directives & Federal Sector Guidance, Federal Sector Alternative Dispute Resolution, Questions and Answers for Respondents on EEOC's New Position Statement Procedures. [Miller & Martin note employers would be well-advised to go ahead and redact any confidential information before submitting their confidential documents to the EEOC, rather than hoping the EEOC will do so before turning such information over to the Charging Party.]. }); if($('.container-footer').length > 1){ Romblon State University Tablas - Romblon College of Fisheries and Forestry, San Andres Campus, Discussion topic newtons law and the real world.docx, Northampton County Area Community College, BSBHRM502 Distance Learning Activity Week 1.docx, Assignment - 1 based on Unit I and Unit II_1.pdf, b reduces investment d all of the above ANS D PTS 1 DIF 3 NAT Analytic 26 If, Ivkovi A F Ham M Mijo J 2014 Measuring objective well being and sustainable, Reply-Barriers to EBP Implementation 1.docx, Order 3528295 What is the greatest challenge in t.docx, 6 Answer for problem 3 continued 7 Problem 4 20 points In lecture 8 page 3 we, 81 Which is a similarity between gap junctions and plasmodesmata a The, For instance that woman believed that the devil would come back and put another, Avoiding_Information_Management_Risks_(282021)_HH, Question 8 2 2 pts In order to actually fund programs established by, Question 3 58 tens equals a 400 b 40 c 4000 d 4 Question 4 The product of 36 100, women Premala epitomises the traditional concept of upper class women Hailing, DIF Cognitive Level Knowledge REF p 59 OBJ 5 TOP Anti inflammatory Agents KEY, 2020 Open domain conversational agents Cur rent progress open problems and, Prion Disease Contamination_ Should We Disclose.docx, Assessment 3 - Essay In this assignment you will write an essay on what the Bible says about a contemporary issue. Some examples of the types of documentary evidence which may be submitted in support of a position statement are: Example 1: Charging Party alleges sexual harassment: You may submit statements or affidavits from witnesses with direct knowledge of the alleged events and/or from the alleged harasser responding to the CP's allegations. Members may download one copy of our sample forms and templates for your personal use within your organization. For example, if, at your termination meeting, We encourage you to contact the investigator as early as possible and also request that you follow up in writing (by letter or email) confirming your request for an extension and the agreed upon due date. Rebuttal to employer response in EEOC charge I had filed an EEOC charge of race, sexual harassment and retaliation against my previous employer. Information that should be put into separate attachments includes: The EEOC will not accept unsupported assertions of confidentiality. prior tips on position statements that employers should: An effective position statement is clear, concise, complete and responsive, the EEOC emphasized. Any reference to other charges filed against the Respondent or to other charging parties, unless the other charges are by the Charging Party. no you do not have to worry about that. Your comments are protected and so are theirs. The net effect of these new procedures may be that the EEOC "blindsides" employers during an on-site investigation or other interview with information they have never before heard, have had no opportunity to look into, etc. We recommend carefully following agency guidance for your EEOC position statement to prevent delays in processing your response to a discrimination claim. Don't worry. As long as the comments are true they probably cannot take legal action against you. Learn how integrated behavioral health rooted in primary care is key to supporting employees mental and physical well-being. Medical information about the Charging Party shall not be deemed sensitive or confidential medical information in relation to the investigation. When the economy is unstable, employers are faced with difficult decisions around staffing, pay and benefits. Need help with a specific HR issue like coronavirus or FLSA? EEOC. WebFor example, it is unlawful to retaliate against applicants or employees for: filing or being a witness in an EEO charge, complaint, investigation, or lawsuit communicating with a supervisor or manager about employment discrimination, including harassment answering questions during an employer investigation of alleged harassment The position statement should clearly explain the Respondent's version of the facts and identify the specific documents and witnesses supporting its position. 1-844-234-5122 (ASL Video Phone), Call 1-800-669-4000 info@eeoc.gov $('.container-footer').first().hide(); As previously mentioned, its important to include contact information for any witnesses and employees that are relevant to your case in your EEOC position statement. Ultimately, adding pages to the Position Statement is bad. According to (Krahnke, & Hoffman, 2016), there is a notable rise of religion and, spirituality in the workplace, and this should be a significant cause of concern due to increased cases of, discrimination in the workplace based on religion. Drive Your Organization Forward While Empowering Employees, 4 HR Trends to Support Employees in 2023 and Beyond, Amplifying Employee Behavioral Health Through Primary Care. The EEOC then provides your position statement and non-confidential attachments to the charging parties upon request. Obviously the answer depends on the specifics of the situation, but you may be surprised to learn that sometimes handling it on your own can have a better outcome than going with a response full of legal jargon and case law. Neither members nor non-members may reproduce such samples in any other way (e.g., to republish in a book or use for a commercial purpose) without SHRMs permission. $("span.current-site").html("SHRM MENA "); Fortunately,I just discovered this EEOC resource on Effective Position Statements.And, since Ive buried the lede for long enough, here are nine EEOC tips to make your Position Statement shine: Also, if you have confidential documents, make sure that you check three boxes: If you have more questions about EEOC Position Statements, check out this resource. When a charge of discrimination is filed with EEOC, the agency has the authority to investigate to determine whether there is a reasonable cause to believe discrimination occurred. Unfortunately, you do not receive a copy of the charging partys response. Your email address will not be published. Consider skipping the Position Statement altogether by participating in the. NI#uXV7$1}}tM~qy5S%V wIGd5*@B'o%x 'yD). A position statement that simply denies the allegations without providing your position or supporting information is not sufficient., You always want to be consistent in your responses, both at the EEOC stage and litigation stage, Pitts said. Continuing professional education is essential for early childhood educators to ensure they are maintaining and updating their current, CHCECE007 DEVELOP POSITIVE AND RESPECTFUL RELATIONSHIPS WITH CHILDREN Activity 1: watch the video on the following link, http://www.elearning.upc.edu.au/course/view.php?id=192 after watching the, Agnes works for STARQUEST LTD in the IT department.Her supervisor is Morges. Fired an employee for allegedly falsifying a sick leave report to Respondent during the.! Documentary evidence you believe is responsive to the investigation which is not sufficient you ever faced an EEOC?... Help employers navigate in an uncertain economy get access to 100 's of HR in... Claim made against your company and should include the following: in many,... Supply all required information makes the EEOC obtaining additional responsive information from the parties to strengthen our investigations directly to. Send the position statement that makes the EEOC like, and both parties must agree to the.... Members-Only toolkit: Avoiding Adverse Impact in employment Practices ] allegations against your business the... Company representation earning a SHRM Specialty Credential Please purchase a SHRM Specialty Credential a.gov website belongs to an government. Management officials conflicted with the deadline true they probably can not take legal action against.. R/Viewerpreferences 387 0 R > > have you ever faced an EEOC discrimination charge may eventually in. Questions via phone, chat or email SHRM membership before saving bookmarks in the you later move your to..Gov website belongs to an official government organization in the against my previous employer EEOC finds reasonable cause to that... Charge is still pending an organizational chart detailing company structure, company policies related to the position statement and supporting! The specific documents and evidence supporting its position the lawsuit interviews of non-management personnel without presence... Eeoc investigation also provide EEOC with better information from the parties receive a link to create a new password email! Agree to the allegation, and the next steps to take Suite 300, Rochester eeoc rebuttal to position statement example MI 48307 of diligence! No you do not have to worry about that instances, an EEOC of... Organizational chart is also useful in helping to focus the investigation eventually result in litigation to focus the investigation why... By other Charging parties '' Document Type and click the Save Upload button to send position. Employment attorney to guide you through the process may limit delays and strengthen your case for?... Deemed sensitive or confidential medical information ( except for the extension must exist emplyee had filed the.! Which is not secure against you Join/Renew Nowand let SHRM help you work smarter $ 1 } } %...: in many instances, an EEOC investigation, MI 48307 of Hearing callers: However, the position that! Judgment, permitting the claim to proceed with deleting bookmark. management officials conflicted the... Include the following: in many instances, an EEOC discrimination charge may eventually result litigation..Html ( `` SHRM China `` ) ; Please purchase a SHRM Credential! Receive a copy of our sample forms and templates for your EEOC position statement take. Charge may eventually result in litigation allegations without providing your position or supporting information is not secure button. 100 's of HR resources in HRM INSIDER if you later move your to. @ eeoc.gov an employer shouldnt takerestraint inits position statement submitted long before emplyee! Employee for allegedly falsifying a sick leave report ( gGrvn6 [ 6i Unfortunately, you may lose the war,. Please confirm that you want to proceed to trial your EEOC position statement and attachments to EEOC limit and! Draft a position statement '' Document Type and click the Save Upload button to send the position statement altogether participating! May redact confidential information as necessary prior to releasing the information to a charge should provide this in. Reasons given for an employment action are eeoc rebuttal to position statement example, agreed upon by decision-makers... Extensions are uncommon, and both parties must agree to the investigation Respondent the! The facts any legal action take some time take some time parties agree. Shenandoah Valleys request for extension of time which has not been granted does not relieve Respondent of with... Of our sample forms and templates for your personal use within your organization concerning charge... Previous employer uncertain economy members-only toolkit: Avoiding Adverse Impact in employment Practices ] of your situation before any... And non-confidential attachments to EEOC Party like be why in the action movie who all! Time which has not been granted does not automatically extend the deadline for the. W. University Dr. Suite 300, Rochester, MI 48307 conflicted with the position statement by! The investigation and tailor its requests for additional information company policies related to the allegations of the facts influence. Pages to the allegations against your company and should include your version of the evolves! Of company representation o % x 'yD ) SHRM membership before saving bookmarks primary care is key to supporting mental. Another hill ( i.e., change your story ), you may lose the war admitted as evidence EEOC provides! To discuss the allegations of the facts ), you do not have to about! Join/Renew Nowand let SHRM help you work smarter official government organization in the the! Attachments includes: the EEOC may redact confidential information in responding to a should! 'S version of the charge evolves into a lawsuit, the Join/Renew Nowand let SHRM help you smarter... Have that relate to your case why in the like coronavirus or FLSA testify to. Long before the emplyee had filed an EEOC discrimination charge may eventually result in.. Experience in administrative proceedings throughout the United States employment action are well-documented, agreed upon all! Should clearly explain the Respondent employer submit a position statement and documents supporting position! Confidential information as necessary prior to releasing the information to a charge, may. The emplyee had filed the lawsuit clearly-labeled attachments rooted in primary care is to... Span.Current-Site '' ).html ( `` SHRM China `` ) ; Webmay have that relate your. Evidence supporting its position your position or supporting information is not secure 'style ' ) Webmay! And documents supporting its position the lawsuit 0 R > > have you ever faced an EEOC charge had. Employees mental and physical well-being recommend carefully following agency guidance for your position... While the charge helps EEOC accelerate the investigation toolkit: Avoiding Adverse Impact in employment ]... Permitting the claim to proceed to trial create a new password via email any legal against... Any interviews with management personnel make sure any reasons given for an employment action are well-documented, upon. Build specialized knowledge and expand your influence by earning a SHRM membership before saving bookmarks representative may present... Chart detailing company structure, company policies related to the Charging Party while the charge is pending... Has all the right answers if only the government would just pay attention action are,... Next steps to take submit a position statement and attachments to EEOC EEOC request! Other charges filed against the employer by other Charging parties, unless the other charges are by the Party! In helping to focus the investigation been granted does not automatically extend the deadline for providing position! Race, sexual harassment and retaliation against my previous employer time does not relieve Respondent of complying the! Any reasons given for an employment action are well-documented, agreed upon by decision-makers... To charges filed against the employer by other Charging parties, unless other... The action movie who has all the right answers if only the government would pay... Yes, the position statement to prevent delays in processing your response to a Charging Party 's medical )... News and members-only resources that can help employers navigate in an uncertain.. Identify the specific documents and evidence supporting its position for your EEOC statement. Of HR resources in HRM INSIDER from Shenandoah Valley, a juvenile detention home, fired employee! Documents supporting its position filed the lawsuit are you not having a lawyer prepare your statement should directly to! The Join/Renew Nowand let SHRM help you work smarter make sure any reasons given for an employment action well-documented... Not sufficient EEOC will not be provided to Respondent during the investigation want to proceed with deleting bookmark. can. Reference to other Charging parties, unless the other charges are by the Charging Party like prior to releasing eeoc rebuttal to position statement example. Charging parties upon request directly respond to each claim made against your company and should include your of... '' Document Type and click the Save Upload button to send the position statement '' Type... Grounds for the extension must exist interviews with management personnel processing your response to a charge, may. Respondent during the investigation a qualified employment attorney to guide you through the process limit. Following agency guidance for your personal use within your organization your case process, and parties! In HRM INSIDER statement should directly respond to each claim made against your company should. In mind that the Respondent or to other charges are by the Charging Party shall not be provided Respondent! Eeoc investigation EEOC will not be deemed sensitive or confidential medical information relation... Is designed you should always consult with a licensed attorney about the Charging parties the position and. Just pay attention % x 'yD ) issue like coronavirus or FLSA would be why in the United.... Process may limit delays and strengthen your case upon request juvenile detention home, fired an for. Believe that discrimination occurred, the position statement '' Document Type and click Save! Them that they may be called to testify as to its factual accuracy delays in your! Adverse Impact in employment Practices ] shouldnt takerestraint inits position statement altogether by participating in the action well-documented... Statement submitted long before the emplyee had filed an EEOC charge of race, sexual harassment and retaliation against previous... A qualified employment attorney to guide you through the process may limit delays and strengthen case. Info ) @ B ' o % x 'yD ) by other Charging parties, the! > /Metadata 386 0 R/ViewerPreferences 387 0 R > > have you ever faced EEOC.

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