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Best EEOC Policies, Programs and Practices in the Private Sector


This document highlights sections of the EEOC Task Force report on Best Equal Employment Opportunity (EEO) Policies, Programs, and Practices in the Private Sector.  The sections featured in this document focus on best practices related to disability.  A best practice promotes equal employment opportunity and addresses one or more barriers that adversely affect equal employment opportunities.

The U.S. Equal Employment Opportunity Commission (EEOC) released the Task Force Report on Best Equal Employment Opportunity (EEO) Policies, Programs, and Practices in the Private Sector on December 22, 1997.  The report identifies best EEO practices of companies around the country and describes their approaches to address workplace discrimination issues.

The Task Force presented employers with the opportunity to showcase the initiatives of which they are particularly proud.  It has been noted that the report will no doubt be of critical assistance to smaller employers without human resource personnel and legal staffs; as well as larger employers who will gain helpful insight from their peers.

Highlighted are a number of companies that the EEOC thought presented noteworthy EEO programs.  In addition, the report discusses partnership arrangements and other types of collaborative efforts involving employers and other groups in achieving EEO worksite objectives.  These partnerships involved a host of players, including government agencies, consultants, schools, individual volunteers, and non-profit organizations.

The Task Force believes there are some exciting and innovative initiatives being offered.  As the Task Force work progressed, it also became clear that a number of companies had taken notable steps in formulating comprehensive EEO and diverse strategies.

In this summary, focus is placed on the best practices where disability was specifically addressed, as well as practices that potentially address the issues of people with disabilities.  In order to retain accuracy, the majority of information extracted is verbatim from the text of the original Task Force report with minor editorial changes.

The text of the Task Force report is available on EEOC's web site at  You can also obtain a copy by writing to EEOC's Office of Communications and Legislative Affairs, 1801 L Street, NW, Washington, D.C. 20507.


This report highlights the activities of ten companies and describes two model employment development programs.  A broad range of activities described by the companies include:

The Task Force stressed that a best practice may not necessarily be universally replicable on a successful basis regardless of employer or industry, or even that the citation of an employer for a best practice does not necessarily mean that it is a problem-free equal employment opportunity employer Amodel.  In other words, a model employer must do many things involving a multitude of areas in a commendable manner.

A review of the reports provided to the EEOC demonstrated the importance of several key components important in assuring equal employment opportunity including:

Ultimately, the most successful companies have learned that it makes the best economic sense to draw talent and ideas from all segments of the population.  Inclusive hiring and promotion practices bring into the organization segments of the workforce that may well provide a competitive advantage in the increasingly global economy.  Systematic exclusion of these segments denies these resources to the organization and lessens the chances of eventual success. For these companies, pursuing diversity and equal employment opportunity is just as integral a business concept as increasing market share or maximizing profits. In this way, diversity and EEO become not just programs, nor even separate departments, but rather a way of life that is integral to all business activities of the company.

Northern States Power Company

Northern States Power (NSP) Company is engaged in the generation, transmission, and distribution of electricity, and natural gas.  Headquartered in Minneapolis, Minnesota, the company has 7,147 employees.

NSP states that it has worked hard to go beyond the disability stereotype that a disability equals a wheelchair to educating employees about other disabilities, including hearing and sight impairments, mental disorders and hidden disabilities.

Company Commitment

Even before the enactment of the Americans with Disabilities Act, NSP indicates that it worked diligently to encourage employees to value, acknowledge and demonstrate respect for one another.


NSP has provided five diversity trainings since 1988, and has required participation of all employees every two years.  NSP includes topic discussions specific to disability status in the trainings.

Reasonable Accommodation

In 1994, NSP became the first large employer in Minnesota to establish a Special Needs Fund to assist employees with disabilities, and to provide them with an alternative means of paying for those rare, high?priced accommodations that ordinarily could strain the budgets of individual departments.  So far the fund has only been used twice.

Promoting Employee Awareness

Employee Networks:  The company supports two internal disability related employee networks.
1)  The NSP/ADA Network.  Employees are responsible for various aspects of ADA compliance and its intention.
2)  The Disability Awareness Network (DANN).  A grassroots employee network which addresses company issues, awareness, and education for the entire workforce.

Awareness Programs:  NSP regularly holds employee awareness programs to further advance its culture change strategy.  It communicates to all company managers the fact that hiring and promotion of qualified people with disabilities, providing reasonable accommodation, and creating or maintaining flexible work arrangements are all linked to managers' incentive pay through NSP=s annual diversity goals-setting process.  NSP=s Customer Service area provides TTY/TDD access and billing materials in large print.

Proactive Recruiting

In recent months, NSP worked with Vail Place to hire two additional mailroom employees.  NSP is currently working with LifeWorks program to fill four administrative positions at the Chestnut Service Center; and has been working with local agencies in the Roseville area to recruit workers with disabilities to fill several part?time positions in that area.

For More Information Contact
Libbey Chiodo
Diversity Specialist
Northern States Power Company
414 Nicollet Mall
Minneapolis, Minnesota 55401
Telephone:  612-330-7957  Fax: 612-330-7935

The Prudential Insurance Company of America

The Prudential Insurance Company of America is one of the largest diversified financial services institutions in the world.  The company offers a full range of insurance, investment, health care, and real estate products and services to both individuals and institutions.  Prudential is headquartered in Newark, New Jersey, and employs more than 90,000 individuals.

Prudential has received special recognition from a number of local and national publications and advocacy groups for opening doors for individuals with disabilities.


One of its efforts is the Pachysandra Project.  This program is a partnership with Our House, Inc., a private nonprofit employment agency.  The program provides supported employment for individuals with developmental disabilities.  Prudential has been able to use the skills of these individuals to meet a number of its business needs. In some cases, positions have been created by a 'carving out' routine, clerical support tasks which were performed by highly paid, professional staff.  This has proven to be a 'win/win' situation.  Programs are being freed from time consuming clerical tasks, while the employee is provided an opportunity to develop useful business skills and earn a considerably higher wage (assuming he/she was previously employed in a minimum-wage job, if employed at all).

Pachysandra Project Components:

For More Information Contact
Louise Sheppard
Director, Equal Opportunity Programs/Human Resources Department
The Prudential Insurance Company of America
751 Broad Street
Newark, New Jersey 07102-3777
Telephone: 201-802-7063

International Business Machines Corporation

The International Business Machines Corporation (IBM), which began in 1914, does business in almost every nation of the world.  The corporation is headquartered in Armonk, New York.  In 1996, IBM had 125,618 regular and complementary employees in the U.S.

IBM is a culturally diverse organization that introduced practices and policies which encouraged workforce diversity several years before it was required by law.  Inclusion has been an integral part of its corporate culture for more than 80 years.  The marketplace is the driving force behind everything that IBM does.  The company is sensitive to the needs of all employees and to the communities in which it operates.


IBM is certain that it is the premier employer in America, having initiated and pioneered numerous Work-Life programs that have become common place in many companies today.  In dealing proactively with issues that are possible impediments to employee attendance, productivity, and loyalty, the company's Work-Life programs are looked at with great pride, and include:

To accomplish flexible working arrangements, the Individualized Work Schedules Program permits employees to begin their workday up to two hours before, or two hours after the normal location start and stop times, providing a four-hour window of flexibility. When employees need to be away from work for an extended period of time, they may take a personal leave of absence for up to three years.  The employees also can reduce their work weeks for a broad array of personal needs, such as dependent care responsibilities, 'once in a lifetime' opportunities, or other individual needs. Employees can perform their work at home or in another offsite location.

Reasonable Accommodations Provided

Examples of reasonable accommodations provided include:

Access to Assistive Technology

A variety of products developed by IBM are used by employees with disabilities, and are also available in the marketplace. Some of the items include:

For More Information Contact
J. T. (Ted) Childs, Jr.
Vice President
Global Workforce Diversity
International Business Machines Corporation (IBM)
Route 9, Town of Mount Pleasant
North Tarrytown, New York 10591
Telephone: 914-332-2280  Fax: 914-332-2115

The Pacific Telesis Group

The Pacific Telesis Group (Pacific Telesis) is comprised of several companies, including Nevada Bell and Pacific Bell that represent over 87% of the Pacific Telesis workforce. The principal services and products of the Pacific Telesis Group are telecommunications related, including local and toll telephone services, data transmission services, and directory publishing. The company is headquartered in San Francisco, California, and has over 50,000 employees.

Pacific Telesis emphasizes its commitment to the goals of equal opportunity for individuals with disabilities, making reasonable and effective accommodations for qualified employees and applicants case by case depending on the individual=s needs and the needs of the business.

Reasonable Accommodation Process

Its structured accommodation process delineates such steps as:

Trained job accommodation specialists are available to provide advice to managers and employees on accommodation issues.  If reasonable accommodation cannot be made within an employee's current position, a job search will be conducted throughout the company for other positions for which the employee is qualified.  A Manager's Guide to Reasonable Accommodation provides Pacific Bell managers with step-by-step instructions as well as advice about what they and the company can do to provide employment opportunities for qualified individuals with disabilities. Pacific Telesis' commitment to reasonable accommodation has prompted consideration of computer voice input technology applications for use by employees with medical restrictions or physical disabilities.


The company has non-salaried (hourly) placement centers.  These centers focus on outreach for minority and/or women applicants, and applicants for non-traditional occupations.  Traditional sources, such as governmental referral agencies and women and minority organizations receive periodic contact, briefing sessions, tours, technical and sales career fairs, and recruiting materials. Pacific Telesis has recruited and hired employees from such organizations as the Asian American Career Fair, Larsen (individuals with disabilities), Northern California Diversity Fair, Urban League, and American Sign Language Foundation.

For More Information Contact
Renea D. Lacy
Manager, EEO/AA Compliance
Pacific Bell, A Pacific Telesis Company
2600 Camino Ramon, Room 2N 154
San Ramon, California 94583
Telephone: 510-867-8506

Owens-Corning Fiberglass Corporation

Owens-Corning Fiberglass Corporation (Owens-Corning) develops, manufactures, and markets advanced glass and composite materials for the building-products and industrial material markets. The company is headquartered in Toledo, Ohio. Owens-Corning employs more than 18,000 persons around the world, with manufacturing, sales, and research facilities in more than 30 countries.

The Owens-Corning Corporation developed an Employee Based Disability Management Program. It emphasizes that its process 'encourages employees with disabilities to return to work' and is in compliance with state and federal laws concerning people with disabilities.  Owens-Corning further emphasizes that Athe program's humanistic nature and emphasis on human dignity is important in preventing employee turnover and maintaining high job satisfaction.

Disability Program

Some of the important components to its disability management and return to work plan include:

Owens-Corning affirms that this program specifically seeks to address barriers to persons with disabilities, both physical and mental and, indeed, is intended to encourage employees with disabilities to return to work. Since January 1993, the total number of disability case managers has risen from one to nineteen (as of Spring 1996). This expansion demonstrates Owens-Corning's commitment to the program's growth and development.

For More Information Contact
Amy Ahrens
Integrated Health Services Leader
Rewards & Resources
1 Owens Corning Parkway
Toledo, Ohio 43659
Telephone: 419-248-8728

U.S. Long Distance Worldwide Communications

U.S. Long Distance Worldwide Communications (USLD) is a long distance telecommunications company, offering direct long distance, operator, prepaid calling card, travel card, data transmission and calling center services.  The company, which has been in business 11 years, is headquartered in San Antonio, Texas, and has 600 employees.

USLD has two core values in its Mission Statement:  1) Employee Appreciation, 2) Community Involvement.  Both core values are taken very seriously and used as tools when recruiting for all positions. USLD works closely with the Texas Commission for the Blind, The San Antonio Lighthouse, and Easter Seals to secure qualified applicants.

Proactive Recruitment of Persons with Disabilities

The company employs 13 visually impaired long distance operators.  Since 1993, The San Antonio Lighthouse has been assisting employees who have been utilizing Braille keyboards and modified computer screens to perform their jobs.  Employees with visual impairments make up 6% of the workforce in USLD's Operator Center.  Visually impaired employees are provided readers, orientation specialists, tape recordings and Braille documentation when hired.

Reasonable Accommodation Required

In addition, the company has invested in adding Braille labels to vending and coffee machines, microwave ovens, restrooms, etc. Work schedules are also customized for employees that rely on bus transportation service.


The company is currently researching various marketing efforts to enhance its marketing, recruitment, and outreach efforts. A special industrial engineering study, conducted by the Texas Commission for the Blind, was recently completed to evaluate two more departments that may offer promotional opportunities for individuals who are visually impaired.

For More InformationContact
Joe Puente
Vice President, Operator Services
U.S. Long Distance Worldwide Communications
9311 San Pedro, Suite 100
San Antonio, Texas 78216
Telephone: 210-525-9009  Fax: 210-525-0389

Price Waterhouse, LLP

Price Waterhouse, LLP (Price Waterhouse) is one of the largest accounting and professional services firms in the country, employing more than 15,000 people.  The firm is headquartered in New York City, but has offices throughout the country.

Price Waterhouse is a member of Project Equality, a program committed to maintaining employment policies and practices that affirmatively promote equal employment opportunity for people of color, women, persons with disabilities, and others who encounter discrimination.

Company Commitment

Price Waterhouse's National Diversity Council was formed in December 1994 to ensure that the leaders in the firm focus on high-priority diversity issues, including work and family issues, and promote tangible results in the day-to-day experiences of each individual at the firm.  Overall, the Council plays a major role in identifying and helping remove any barriers that may prevent the environment from being one that supports and provides opportunity for everyone in the firm; integrating diversity and lifestyle initiatives into every practice office; and incorporating these efforts into the operating plans at all levels of the firm.

Flexible Work Arrangements

Price Waterhouse has a host of programs and initiatives to support its employees.  It offers a variety of flexible work arrangements that are used to accommodate diverse personal situations such as:

More than 800 people in the firm, including two partners and 100 women managers, are officially using some form of these arrangements.

Health Care Initiative

Price Waterhouse is one of 21 'champion' companies, that has partnered to form, The American Business Collaboration for Quality Dependent Care.  This 'partnership' has collectively pledged $100 million over six years to improve the quality and quantity of dependent care in communities across the country where its employees live and work.  More than 400 staff use the firm's dependent care services.

Flexible Leave Policies

Price Waterhouse provides for paid sick leave for up to three months as a result of illness, injury, or pregnancy.


Price Waterhouse offers diversity education to everyone in the firm to raise and maintain a high level of awareness and help people in the firm improve their communication and relationship-building skills in order to work more effectively with each other and with its multi-national clients.  Nearly 1,800 staff members participated in diversity education programs.

For More Information Contact
Sharon J. Robinson
Manager, Diversity & Work-Life Programs
Price Waterhouse
1177 Avenue of the Americas
New York, New York 10036
Telephone: 212-596-7000

The Rouse Company

The Rouse Company (Rouse), headquartered in Columbia, Maryland, is one of the largest publicly held real estate development and management companies in the United States.  Founded in April 1939, the company has over 5,000 employees.  Rouse operates 192 properties encompassing office, retail, research and development, industrial, and hotel space.  The properties are in 24 states, the District of Columbia, and Canada; and they have an asset value exceeding $4.7 billion.

Rouse promotes a variety of programs to attract a diverse workforce, and to support the balancing of work, life, and family responsibilities.

Flexible Work Schedules

Alternate Work Schedules, include:  part-time, temporary, on-call, telecommuting, job sharing and flextime.

Wide Range of Benefits

Flexible benefit packages are offered, which, when provided by Rouse in 1983, marked Rouse as the first in the State of Maryland to offer a full program of flexible benefits to meet the individual needs of the workforce.  These benefits include Child and Elder Care Pre-Tax Spending Accounts, Health Insurance, Time-Off with Pay (i.e., vacations, floating holiday, occasional absence, sick leave, and retiree benefits).

Individual Assistance Programs are available to everyone in the company and their dependents.
The programs include:  human relations problems, such as emotional or behavioral disorders, family and marital discord, alcohol and drug abuse, financial, legal, work-related and other personal problems.

Time-Off-With-Pay Benefits, which, when it is necessary, excuses an employee from work for short periods of time to take care of personal matters.  The company's time-off benefits include, but are not limited to occasional absences for parental commitments, sick leave (96 hours per year for illness of the employee), short term disability, and long term disability.

For More Information Contact
William D. Boden
Vice President
Director of Human Resources and Administrative Services
The Rouse Company
10275 Little Patuxent Parkway
Columbia, Maryland 21044
Telephone:  410-992-6511  Fax:  410-964-3436

The Bureau of National Affairs, Inc.

The Bureau of National Affairs, Inc. (BNA) is a publishing company based in Washington, DC. BNA produces over 200 highly technical, specialized information services in print and electronic formats. These services are intended to provide accurate, comprehensive information on all major developments in labor, legal, tax, economic, environmental, safety, and health activities of the nation.  The more than 1,600 employees (500 of whom are reporters and editors) are represented by the Washington-Baltimore Newspaper Guild.  A subsidiary company, BNA Communications, produces a line of products focusing on EEO and diversity issues.

BNA states that it is committed to complying with the Americans with Disabilities Act, and makes every reasonable accommodation for persons with disabilities, including employees, applicants, and visitors to their buildings.

Management Commitment and Accountability

The president of BNA has issued formal policy statements on affirmative action, equal employment opportunity, and on sexual harassment.  The text of these statements appear in the BNA Handbook, and they also are posted on bulletin boards throughout the company.  BNA states that its managers are held accountable for their EEO performance and are trained to understand and utilize the special strengths of a culturally diverse workforce.  An important part of the orientation for new employees is a briefing by BNA's EEO Officer on the company's anti-discrimination and affirmative action policies and complaint procedures.  BNA says that it is committed to being a leader in the fair treatment of all and in innovative programs to maximize the potential of all.  The company pledges to ensure the fairness of its promotional system.

Employee Programs

BNA's Human Resources Training and Development Group has put together a number of programs which provide employees the opportunity to develop professionally and personally, including:

Health Insurance

BNA feels that its health insurance coverage is among the best in the United States.  There are no employee contributions for coverage under BNA's health plan for employees or their dependents. In addition, employees may register domestic partners as their eligible dependents under one of the health plans offered by BNA.  The company also has both medical care and dependent care spending accounts that enable participants to pay for dependent care with pre-tax dollars.

Family and Medical Leave Act

BNA indicates that it goes far beyond compliance with the provisions of the federal Family and Medical Leave Act, which allows employees to take up to twelve weeks of unpaid leave for childbirth, adoption, or a serious medical condition.  Employees can take advanced sick leave, if a doctor designates a medical need, up to the amount of accumulated annual leave.  They also can use all accumulated annual leave, three days of personal leave, and six months or more of leave without pay.

Open Discussion of Diversity Issues

Brown-bag lunches to discuss diversity issues were started over five years ago by a group of BNA employees. These lunches give all BNA employees an opportunity to come together to informally discuss issues concerning diversity in the workplace and the community outside of BNA.

For More Information Contact
Anthony A. Harris
Director of Employment & Diversity
Human Resources Department
The Bureau of National Affairs, Inc.
1231 Twenty-Fifth Street, Northwest
Washington, DC 20037
Telephone:  202-452-4200  Telex:  285656 BNAI WSH

Bausch and Lomb

Bausch and Lomb (B & L) develops and produces eye care products and precision optical devices, and provides specialized biomedical products and services which help diagnose and treat various diseases.  Founded in 1853 in Rochester, New York, where corporate headquarters remains today, B & L employs approximately 13,000 people in 35 countries.

B & L has implemented strategies and tactics which demonstrate its commitment to work-life issues.

Flexible Policies

Alternative work arrangements, which include compressed work week, flextime, job sharing, reduced hours, and telecommuting.

Employee Assistance

For More Information Contact
Fiona Wong
Human Resource Representative
Corporate Human Resources, Operations
One Bausch and Lomb Place
Rochester, New York 14604-2701
Telephone: 716-338-6000

Bridges From School-To-Work

Bridges from School-to-Work (Bridges) is sponsored by the Marriott Foundation for People with Disabilities, and administered by TransCen, Inc. (TransCen), a private, not-for-profit corporation. The major thrust of TransCen's work is to enhance the ability of youth with disabilities to successfully transition from school to work.  TransCen has been charged with establishing collaborative relationships among government, education, private agencies, advocacy groups and employers, which facilitate the development, implementation and evaluation of model efforts that increase opportunities for the employment of people with disabilities.  Bridges' offices include the main office in Rockville, MD and programs operating in Fairfax, VA, Washington, DC, San Francisco, CA, Los Angeles, CA, Atlanta, GA, and Chicago, IL.

The Bridges program gives young people with disabilities the opportunity to learn, grow, and succeed through a project that involves employers, schools, students and their parents. There is no fee to the participants, students or employers.

Program Purposes


Education, training, and support, focusing on internships, are central to the Bridges model. To prepare the student interns for the workplace, the program provides orientation and training for the students and their parents. To assist employers, Bridges conducts disability awareness training that addresses workplace issues such as communication, supervision, and discipline. To support the internships, Bridges employer representatives help identify appropriate positions, match student interests and capabilities with job requirements, and provide ongoing assistance to employers and interns.

More specifically, TransCen, the administrator of Bridges, directs all aspects of the programs through local Bridges project directors and employer representatives who:

The Employer

The School System

Over 3,000 youth have participated in this employer-driven internship program since it began in 1990. Some 900 employers have participated. Bridges has assisted young adults in finding employment in a variety of occupational areas. These jobs have included: administrative assistant, data entry clerk, carpenter's assistant, day care aide, editorial assistant, security officer, retail clerk, dietary aide, mechanic, printer's assistant, animal care assistant, receptionist, hotel house person, theater attendant, library assistant, and landscape assistant.

For More Information Contact
Steven P. Mathis
Employer Representative
Bridges from School-to-Work
451 Hungerford Drive, Suite 700
Rockville, Maryland 20850
Telephone: 301-424-2002

Maine Medical Center

Maine Medical Center (MMC) is a 59-bed nonprofit teaching hospital located in Portland, the largest city in Maine.  MMC is the largest hospital in Maine, and the third largest private employer in the state. It provides a full range of medical services to the community, and is the major referral center for Maine and parts of New Hampshire.

MMC is also a member and project leader of a consortium of employers that began in 1993 to promote employment for people with psychiatric disabilities.

Employment Programs

MMC assists employers in the job placement of persons with psychiatric disabilities.  More specifically, the MMC Hospital Industries Program (HIP) has been successfully using the individual-placement-supported-employment model of vocational rehabilitation.  The model includes:

In addition, using the place-train model, MMC serves 50 persons with psychiatric disabilities per year and has placed people in 70 businesses throughout Maine.  MMC also has a program of employment development for youths with emotional and cognitive disabilities, which has been in existence for nine years. It recognizes the support of people with psychiatric disabilities must go beyond the rehabilitation service and include the worksite.

The purpose of the program is to determine how the consortium of employers can collectively:

Consortium member representatives are human resource managers from each institution or company. In addition, there are representatives of the Maine State Department of Mental Health and Mental Retardation, a mental health consumer who is employed, and the Augusta Mental Health Institute. The program is being conducted under the auspices of the HIP.

MMC, as the project leader, works with the representatives from the human resource offices to determine:

In implementing the program, alternative strategies are developed and tested in the group of cooperating employers for expanding development, training, and employment opportunities. Training, planning assistance, and evaluation for human resources personnel and others responsible for recruitment, hiring, training, and oversight of personnel are provided. Accordingly, for example, employment specialists work with the employers to develop natural supports and reasonable accommodations.  Education of co-workers and support for training of target constituencies are also provided.

For More Information Contact
Richard M. Balser
Director, Department of Vocational Services
Administrative Director, Department of Psychiatry
Maine Medical Center
22 Bramhall Street
Portland, Maine 04102-3175
Telephone: 207-871-2088


The following are recommendations based on a sampling of the characteristics that seem to be common in most of the companies that operate their EEO compliance procedures above and beyond the minimum basic legal requirements.

Conduct training programs in EEO rights and responsibilities including, but not limited to:


Since one cannot solve problems one does not know exists, it is important to:



Senior, middle, and lower management must champion the cause of diversity and provide not only symbolic but actual leadership for its implementation.  One can promote equal employment opportunity and diversity, not only as a morally and legally correct thing to do, but importantly, as a business imperative.  Accordingly:


Companies should encourage proper action by all managers, supervisors, and employees. Business practices and reward systems should be structured to promote diversity.  If a diverse workforce is desired, behaviors that promote diversity must be rewarded.  In this way, organizations will truly get what they pay for.  Accordingly:


Take notice of the impact of your practices.  Self-analysis is a key part of this process.  Accordingly:


Communicate and reinforce the message that diversity is a business asset and a key element of business success.  Accordingly:


Bring everyone into this process; leave no one behind. Accordingly:


Long term gains from these practices may cost in the short term.  Accordingly:

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