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The National Law Journal asked four corporate counsel: How do you and your staff communicate company goals in complying with Title VII and other fair employment standards? Their overall advice was to keep lines of communication open using both words and actions — beginning at new employee orientation and continuing through management training seminars. David B. Siegel, senior vice president, general counsel and chief restructuring officer, W.R. Grace & Co., Columbia, Md. At Grace, promoting compliance with Title VII and other fair employment laws is very much a partnership among management, our human resources (HR) personnel and our in-house attorneys. Grace management communicates to employees its commitment to a set of core values, which include treating all people with respect and holding people accountable for their actions. Our in-house attorneys work with our HR personnel to prepare educational materials regarding fair employment laws, which are communicated to employees through a variety of methods, including the Grace intranet and face-to-face meetings. Our in-house attorneys hold seminars with managers at all levels to educate them on their responsibilities under fair employment laws and to make sure they understand how these laws are applied in various contexts such as hiring, periodic employee performance reviews, daily workplace conduct and termination of employment. We believe that compliance with fair employment laws helps our businesses achieve valued goals, including making merit-based employment decisions.

Daniel Cooperman, senior vice president, general counsel and secretary, Oracle Corp., Redwood City, Calif. Oracle promotes a collaborative work environment by communicating its policies, business ethics and employment practices through an interactive online Web training program available to all employees and managers. The program contains several discrete courses, including one on equal employment opportunity. The course provides comprehensive information about Oracle’s nondiscrimination and EEO policies, the employee’s responsibilities under these policies and the process for reporting incidents. The course is recommended for all employees. Further, we explain the importance of complying with fair employment standards in our ethics guide, employee handbooks, manager’s resource guide and a variety of management training courses. Rosalind Gordon, labor counsel, Pitney Bowes Inc., Stamford, Conn. The HR Legal group emphasizes Pitney Bowes’ commitment to Title VII and to fair employment practices at every opportunity and by every means available to us. Pitney Bowes’ EEO policies can be found on the Internet, on our intranet, in our hiring packages, our job advertisements and our postings. The company’s goals in this regard are also regularly communicated through HR personnel, management and employee training on the topics. In addition, when working with HR professionals and managers regarding routine employee-relations issues, Title VII and its mandates are regularly discussed. We ask that when making every employment-related decision that our professionals make sure that they consider Title VII, fair business practices and Pitney Bowes’ strict ethical standards. All our business units provide sexual harassment and EEO training to their managers (and usually to their nonexempt employees as well). Additionally, some of our business units have a detailed, formal training program. We provide leadership training to all managers through a program called LEAD, of which fair employment is a foundation.

� Bart Schwartz, senior vice president and general counsel, The Mony Group Inc., New York Compliance with the employment laws has always been a high priority for me and for the companies I have served as general counsel. By developing a close working relationship between the legal department and HR, we have worked hard to make sure that the company and each of its business units have adopted and implemented strong policies and procedures to prevent and promptly correct sexually harassing behavior. These policies and procedures should meet the EEOC’s minimum standards. There must also be clear, well-implemented policies and procedures to protect against unlawful employment discrimination and to ensure compliance with the Fair Labor Standards Act. What is critically important in this and other compliance areas is that the policies are not simply words written down on a piece of paper that is kept in some file cabinet, but that there is real and meaningful ongoing implementation through periodic training, assigned accountabilities and consistent enforcement and follow-through. This means regular communication of the policies and procedures, starting with each employee’s initial orientation and including periodic updates and refreshers. It also means vigor and consistency in responding to complaints. So, communication takes place at every level through the company’s words as well as the company’s actions in responding to employment law issues.

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