Equal Employment Opportunity Policy

1. Diversity and Inclusion: Legal Aid of North Carolina wants to ensure that diversity and
   inclusion are a priority in how we conduct business, practice law, and connect with our
   communities. We define diversity and inclusion broadly to mean the goals of accepting,
   respecting and valuing differences that may include attributes such as race, color, age, gender,
   national origin, religion, sexual orientation, gender identity and expression, disability, language,
   marital and familial status, and ethnic and cultural background.
   LANC strives to offer a workplace that includes excellent staff and management from all
   cultures, lifestyles and experiences, acting on the belief that an inclusive work environment
   provides an atmosphere that allows all individuals to attain their greatest potential and achieve
   the greatest benefits for clients.
   
   We appreciate and value ideas that come from a diverse work environment and want to bring
   diversity of thought, experience, and expertise to bear on everything we do.
   We infuse the principles of diversity and inclusion in community partnerships and outreach,
   client contact, strategic planning, hiring, promotion, retention, and staff and board operations at
   every level. We also periodically review and modify our policies, procedures and practices to
   improve our efforts to promote diversity and inclusion as well as draft new policies whenever
   necessary to achieve our diversity and inclusion goals.
   
   We are committed to creating workplaces in which staff in all positions and job titles are
   culturally sensitive and diverse so we can better serve our clients LANC will make every effort to
   ensure that its existing and new office spaces are accessible to physically disabled clients, staff
   and volunteers.
   
2. Non-Discrimination. It is the policy of LANC and its Board of Directors to not discriminate
   against any person in matters of employment on any basis prohibited by law. No employee or
   applicant for employment shall be discriminated against in matters of employment opportunity,
   hiring, compensation, fringe benefits, promotional opportunities, access to training and
   educational programs or other terms and conditions of employment on the basis of sex, race,
   color, national origin, religion, age, disability, marital or familial status, union activity, sexual
   orientation, gender identity and expression, or any basis prohibited by law. No employee shall
   be subject to sexual harassment. Reasonable accommodations shall be made for employees
   with disabilities as set out below.
   
3. Sexual Harassment. Sexual harassment is defined as unwelcome sexual advances, requests for
   sexual favors, and other verbal or physical conduct of a sexual nature when submission to such
   conduct is explicitly or implicitly made a term or condition of employment or is used as a basis of
   employment decisions or such conduct has the purpose or effect of unreasonably interfering
   with an individual’s work performance or creating an intimidating, hostile or offensive working
   environment. Employees who believe they have been subjected to sexual harassment should
   report the act to their Managing Attorney, Senior Managing Attorney, Regional Managing Attorney or the Executive Director. Any complaint relating to the Executive Director should be
   reported to the Chairperson of the LANC Board of Directors.
   
4. Accommodations for Employees with Disabilities. LANC will comply with the federal law and
   the requirements of Legal Services Corporation regulation 45 CFR 1624, as amended from time
   to time. Reasonable accommodations shall be made to the known physical or mental limitations
   of an otherwise qualified employee with a disability unless to do so would impose an undue
   hardship on LANC’s operations. As federally defined, disability is a) a determinable physical or
   mental characteristic of an individual that may result from disease, injury, congenital condition,
   or functional disorder that substantially limits one or more of the major life activities of the
   individual to perform the essential job functions; b) a history or record of a determinable
   physical or mental characteristic; or c) being regarded as having a determinable physical or
   mental characteristic. An employee who believes that he or she has a physical or mental
   limitation for which an accommodation should be made should notify his or her Managing
   Attorney, Senior Managing Attorney, Regional Managing Attorney or the Executive Director of
   the limitation and the accommodation that is desired.

B. RESPONSIBILITY FOR EEO POLICY

1. Board of Directors. The Board of Directors has overall responsibility for adoption, revision and
   oversight of the LANC Equal Employment Opportunity Policy.
   
2. Personnel Committee. The Personnel Committee of the Board of Directors has responsibility
   for periodic review of LANC employment practices to ensure that the Equal Employment
   Opportunity Policy is observed.
   
3. Executive Director. The Executive Director has responsibility for the designation of the Equal
   Employment Opportunity Officer, and implementation of the LANC Equal Employment
   Opportunity Policy including any procedures and Affirmative Action Plan that may be adopted
   pursuant to this policy.
   
4. Equal Employment Opportunity Officer. Designated by the Executive Director, the Equal
   Employment Opportunity Officer has responsibility for presenting the report to the Executive
   Director and the Personnel Committee of the Board of Directors for its annual EEO Review and
   to act as a resource on LANC’s EEO Policy and any Affirmative Action Plan that may be adopted.

C. RESOLUTION OF EEO COMPLAINTS

1. Employees. Any grievance alleging a violation of this policy may be presented for resolution under the LANC Employee Grievance Procedure.
   
2. Applicants for Employment. An applicant for employment by LANC who is not hired and who asserts to the Executive Director of LANC that the decision not to hire him or her was based upon discrimination prohibited by the LANC Equal Employment Opportunity Policy shall be informed that he or she may present the claim of discrimination to the Board of Directors Personnel Committee pursuant to the LANC Employee Grievance Procedure. The appeal shall be limited to the claim of discrimination, and may not generally address the propriety of the hiring decision made by the hiring committee or the Executive Director, except to the extent relevant to the claim of discrimination.
   
3. No Retaliation. Any incident of discrimination or harassment should be reported in confidence to the employee’s Managing Attorney, Senior Managing Attorney or Regional Managing Attorney so that an immediate investigation can be conducted. An employee may also directly contact the Executive Director or the Chairperson of the Board of Directors. Allegations of discrimination shall be handled in accordance with the grievance procedures established pursuant to this Policy. There shall be no retaliation against any employee for reporting incidents of discrimination or harassment or for providing information regarding an incident reported by another employee.

D. ANNUAL EEO REVIEW AND AFFIRMATIVE ACTION PLAN

1. Annual Report. Every year, prior to the third Board meeting, the Equal Employment Opportunity Officer shall present a report to the Personnel Committee of the Board of Directors including at least the following information at the time of the report: (1) a comparison of LANC’s work force, showing proportions of the work force by race and sex to similar data from LSC; (2) age data for the entire LANC staff ; (2) data for new permanent hires to the work force and terminating staff departures from the work force, by race and sex for all LANC employees for the period since the date of the last report, (3) a case summary of each grievance by any applicant for employment or employee which raises a claim of discrimination, including a statement of the claim and status or resolution of the grievance; and (4) any recommendations that the Committee or Board take action pursuant to or amend the Equal Employment Opportunity Policy. The Annual Report relies on self-reporting of race and sex by employees.
   
2. Personnel Committee Review. The Personnel Committee of the Board of Directors shall review the Annual Report, and shall request and review such other information as it deems appropriate. If the Committee determines that the proportion of minorities and women in the LANC work force at the time of the report or the number of minorities and women entering or departing from LANC employment since the last report is not consistent with LANC’s EEO policy, it shall review the recruiting, hiring, training and promotional practices to determine if discrimination has occurred and make a plan for Affirmative Action based upon the evaluation described above, to eliminate the discriminatory practices which have been identified.
   
3. Board of Directors Review. At the conclusion of its review, the Personnel Committee shall report on the status of EEO to the Board of Directors, including any recommendations that the Board take action pursuant to or amend the Equal Employment Opportunity Policy, or that any Affirmative Action Plan developed as set out above be adopted. If an Affirmative Action Plan is adopted by the Board, the Executive Director shall implement the plan and shall report on the status of the plan to the Personnel Committee of the Board on a periodic basis, not less than annually, and to the full Board on request.