I. Purpose

The National Asian Pacific Center on Aging (NAPCA) is committed to providing a safe, inclusive, and welcoming environment for all individuals. NAPCA prohibits discrimination, harassment intimidation or retaliation on the basis of race, color, national origin, religion, ancestry, ethnic group, identification, sex, gender, disability, medical condition, marital status, veteran’s status, or age. This policy is based on rights protected by 40 C.F.R. Parts 5 and & (Nondiscrimination in Programs or Activities Receiving federal Assistance from the Environmental Protection Agency) to include:

• Title VI of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000d et seq., 40 C.F.R. Part 7;

• Title IX of the Education Amendments of 1972, as amended, 20 U.S.C. §§ 1681 etseq., 40 C.F.R. Part 5;

• Section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. § 794, 40C.F.R. Part 7;

• the Age Discrimination Act of 1975, 42 U.S.C. §§ 6101 et seq., 40 C.F.R. Part 7,Subpart F, and

• Section 13 of the Federal Water Pollution Control Act of 1972, Pub. L. 92-500 § 13,86 Stat. 903 (codified as amended at 33 U.S.C. § 1251 et seq. (1972)), 40 C.F.R. Part 7.

II. Scope

This policy applies to all members of the public, including program participants and enrollees, and other stakeholders, who believe they have been subject to discrimination or harassment.

III. Principles

All employees, volunteers, contractors, vendors of NAPCA have a responsibility to always treat others with dignity. All individuals are expected to exhibit conduct that reflects inclusion during work, at work functions (on or off the work site), and at all other company-sponsored and participative events. Any employee found to have exhibited any inappropriate conduct or behavior against others that is inconsistent with the scope and intent of this policy or applicable laws may be subject to disciplinary action.

NAPCA practices and policies on recruitment and selection; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; layoffs; and terminations encourages and enforces:

• Fairness: All grievances will be handled impartially and justly.

• Communication: Respectful communication and cooperation between all partiesas it relates to diversity, equity, and inclusion.

• Confidentiality: Grievances will be kept confidential to the extent possible.

• Non-Retaliation: Complainants will not face retaliation for filing a grievance. Teamwork and employee participation is expected, permitting the representation of all groups and individuals’ perspectives.

NAPCA is prohibited from retaliating against any member of the public who files a complaint under these procedures and any retaliation will be handled promptly if it occurs.

IV. Grievance Procedure

Step 1: Informal Resolution

1. Initial Contact: Individuals are encouraged to first address their concerns informally by contacting the staff member or department involved.

2. Documentation: NAPCA staff should document all correspondence and resolution attempt.

Step 2: Formal Complaint Filing

1. Submission: If the issue is not resolved informally, a formal grievance can be filed by the complainant in writing within 120 calendar days after the alleged violation. The formal grievance should contain information about the complainant and the alleged discrimination such as:

• The name, address, and phone number of complainant

• The name of the NAPCA department and/or employee(s) against whom the complaint is filed;

• The location, date, and description of the alleged violation; and 

• The signature of the complainant or their designee.

Submit the written grievance in person, by mail, or via email to NAPCA’s designated Non-Discrimination Coordinator:

Angela Kuo, Senior Manager, Administration

1511 Third Ave #914 

Seattle, Washington 98101-1626 

Contact Number: (206) 752-8946 

Email: hr@napca.org

If the complainant is unable to submit the complaint in writing, they may call NAPCA’s Non-Discrimination Coordinator to submit a verbal complaint. NAPCA will take reasonable steps to provide meaningful access for limited English proficient individuals and individuals with disabilities.

The Non-Discrimination Coordinator may attempt to conciliate and resolve the complaint through a mutually agreeable solution. Any such informal resolution will be signed by both NAPCA’s President/CEO or designee and the complainant. Absent extenuating circumstances, the Non-Discrimination Coordinator will complete their investigation and resolution efforts promptly.

Step 3: Acknowledgment

1. Receipt Confirmation: NAPCA’s Non-Discrimination Coordinator will acknowledge receipt of the grievance in writing.

2. Initial Review: Conduct an initial review to ensure the grievance falls within the scope of this policy or whether the complaint has sufficient merit to warrant an investigation.

Step 4: Investigation

1. Interview: During the investigation, the Non-Discrimination Coordinator generally will interview the complainant and the accused, conduct further interviews as necessary and review any relevant documents or other information. Upon completion of the investigation, NAPCA will determine whether this policy has been violated based upon its reasonable evaluation of the information gathered during the investigation. The Non-Discrimination Coordinator will inform the complainant and the accused of the results of the investigation.

2. Gather Information: The Non-Discrimination Coordinator will collect relevant information, documents, and statements.

3. Confidentiality: Confidentiality will be maintained throughout the process.

Step 5: Resolution

1. Decision: Based on the investigation, a decision will be made regarding the grievance.

2. Written Response: The complainant will receive a written response with a summary of the allegations, and investigation of the alleged complaint, and any remedial action to be taken by NAPCA.

3. Timeline: NAPCA will make every effort to resolve the complaint within 6 months from the date of acknowledgment to written resolution unless otherwise stated. If a delay is expected, the Non-Discrimination Coordinator will notify the complainant in writing of the reasons for the delay and expected date of response.

Step 6: Appeal

1. Appeal Process: If the complainant wishes to appeal, they may file an appeal within 30 calendar days of receiving the decision.

2. Review: The appeal will be reviewed by a higher authority within NAPCA and should be sent to: Polly Colby, Managing Director, pcolby@napca.org, 206-704-5421.

3. Final Decision: A final decision will be provided in writing.

V. Monitoring and Evaluation

The Non-Discrimination Coordinator shall maintain records of complaints received, informal resolutions, investigation findings, appeals, and appeal decisions. The Non- Discrimination Coordinator shall document actions taken to resolve each complaint, communicate complaint activity to the appropriate federal agency as required, and maintain copies of complaints and documentation of their resolution for a period of not less than two (2) years.

Tracking System: Grievances will be logged and tracked to monitor resolution and identify any patterns.

Review and Update: This policy will be reviewed annually and updated as necessary based on feedback and regulatory changes.

VI. Compliance

This policy complies with all relevant federal regulations and guidelines, ensuring our practices align with federal standards.

An appropriate, prompt, and impartial investigation of any allegations filed under federal non-discrimination statutes will be conducted. A preponderance of the evidence standard will be applied during the analysis of the complaint.

If a delay is the process is expected, the Non-Discrimination Coordinator or designee will notify the complainant in writing of the reasons(s) for the delay and the expected date for a response.

These procedures do not deny the right of the complainant to file a complaint with state or federal agencies, or to pursue litigation for complaints alleging discrimination, intimidation, or retaliation of any kind that is prohibited by law. Nor will these procedures supersede any other federal, state or local employment law, nor does it apply to administrative actions that are being pursued in another forum.