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Non-Discrimination Policy

Title VI Non-Discrimination Policy Statement

Jewish Vocational Service is committed to ensuring that no person is excluded from or denied the benefits of our services on the basis of race, creed, color, age, national origin, ancestry, disability, marital status, domestic partnership or civil union status, veteran or military status, religion, sexual orientation, gender, gender identity, alienage or citizenship status as protected by federal and state law. Any person who believes that they have individually, or as a member of any specific class of persons, been subjected to discrimination on the basis of any of the above categories may file a complaint in writing to Jewish Vocational Service.

Jewish Vocational Service has 15 business days to investigate the complaint. If more information is needed to resolve the case JVS may contact the complainant in writing. The complainant has 15 business days from the date of the letter to send requested information to the investigator assigned to the case. If the investigator is not contacted by the complainant or does not receive additional information within 15 business days, JVS can administratively close the case. A case can be closed if the complainant no longer wishes to pursue their case.

To file a complaint, or for more information on Jewish Vocational Service’s obligations under state and federal anti-discrimination laws write to: 354 Eisenhower Parkway Suite 2150 Livingston, NJ 07039. A person may also file a complaint directly with the Federal Transit Administration at:
FTA Office of Civil Rights
1200 New Jersey Avenue SE
Washington, DC 20590

For information in another language, contact 973-674-6330
Si informacion se necesita en otro idioma, harne 973-674-6330

This form is available in Spanish.
Este forumulario está disponible en espanol.

Download a copy of the Title VI Complaint Form.
Effective date: 12/18/2015

Submit form and any additional information to:
Jewish Vocational Service
7 Glenwood Ave., Lower Level
East Orange, NJ 07017

Antidiscrimination Complaint Procedures

Jewish Vocational Service has established the following procedure for lodging a complaint of harassment, discrimination or retaliation. The agency will treat all aspects of the procedure confidentially to the extent reasonably possible.

An individual who feels harassed, discriminated or retaliated against may initiate the complaint process by filing a complaint in writing with JVS’s human resource (HR) department. No formal action will be taken against any person under this policy unless HR has received a written and signed complaint containing sufficient details to determine if the policy may have been violated.

The complainant (the person making the complaint) may obtain the complaint form from the JVS website or the HR department. If an employee becomes aware that harassment or discrimination is occurring, either from personal observation or as a result of an individual coming forward, the employee should immediately report it to their supervisor or the HR department.

Upon receiving a complaint or being advised by a supervisor or employee that violation of this policy may be occurring, the HR manager will notify the agency and review the complaint with the company’s legal counsel. Within five working days of receiving the complaint, the HR manager will notify the person(s) charged [hereafter referred to as “respondent(s)”] of a complaint and initiate the investigation to determine whether there is a reasonable basis for believing that the alleged violation of this policy occurred.

During the investigation, the HR manager, together with legal counsel or other management employees, will interview the complainant, the respondent and any witnesses to determine whether the alleged conduct occurred.

Within 15 business days of the complaint being filed (or the matter being referred to the HR manager), the HR manager or other person conducting the investigation will conclude the investigation and submit a written report of his or her findings to the agency.

If it is determined that harassment or discrimination in violation of this policy has occurred, the HR manager will recommend appropriate disciplinary action. The appropriate action will depend on the following factors: a) the severity, frequency and pervasiveness of the conduct; b) prior complaints made by the complainant; c) prior complaints made against the respondent; and d) the quality of the evidence (e.g., first-hand knowledge, credible corroboration).

If the investigation is inconclusive or if it is determined that there has been no violation of policy but potentially problematic conduct may have occurred, the HR manager may recommend appropriate preventive action. Within five days after the investigation is concluded, the HR manager will meet with the complainant and the respondent separately, notify them of the findings of the investigation, and inform them of the action being recommended.

The complainant and the respondent may submit statements to the HR manager challenging the factual basis of the findings. Any such statement must be submitted no later than five working days after the meeting with the HR manager in which the findings of the investigation are discussed. Within 10 days from the date the HR manager meets with the complainant and respondent, the company will review the investigative report and any statements submitted by the complainant or respondent, discuss results of the investigation with the HR manager and other management staff as may be appropriate, and decide what action, if any, will be taken.

The HR manager will report the agency’s decision to the complainant, the respondent and the appropriate management assigned to the department(s) in which the complainant and the respondent work.

The agency’s decision will be in writing and will include findings of fact and a statement for or against disciplinary action. If disciplinary action is to be taken, the respondent will be informed of the nature of the discipline and how it will be executed.

For information in another language, contact 973-674-6330.
Si informacion se necesita en otro idioma, harne 973-674-6330.

This form is available in Spanish.

Title VI Investigations Complaints and Lawsuits

Jewish Vocational Service 2014-2015

 

Date
month/day/year

Summary
Includes basis of complaint: race, color, religion, national origin.

Status

Actions Taken

Investigations

       
1        
2        

Lawsuits

       
1        
2        

Complaints

       
1        
2        

Title VI Public Participation Plan

Jewish Vocational Service publishes notices, brochures and tables regarding JVS’s proposals and programs, including how the public can obtain information and make comments, where meetings are to take place, and other applicable information. The notices for public input are posted 30 days in advance so the public has time to consider proposals and make comments. The notice methods include:

  • Press releases to local and state media
  • Customer newsletters (print and e-mail)
  • Website links and articles
  • Meetings conducted on a regular basis for agency consumers at agency location
  • Sign language translators always in attendance for hearing impaired consumers
  • Annual reporting of service outcomes

JVS’s Title VI Non-Discrimination Policy, complaint procedure and complaint forms are available on the internet, transportation vehicle and common areas of the service location-both in Spanish and English.

All public meeting locations are accessible to those individuals with disabilities.

On important issues, such as service changes, JVS conducts meetings that involve all program service recipients organized into one group, since we only run one vehicle. Time is allotted for staff to present information and receive feedback from all service recipients. The stakeholder satisfaction survey results and annual reports on program outcomes are presented at the Board of Trustee Committee meetings so they can participate in the decision-making process.

Language Assistance Plan

JVS is responsible for the management of the County’s JVS local bus service, JVS commuter bus service and JVS paratransit service. The County is the Primary Recipient of funds from the Federal Transit Administration (FTA) for the purpose of providing public transportation. Sub-Recipients within the County receive their FTA funds for public transportation through the County. The sub-recipients include the service area for the JVS service, This Language Assistance Plan (LAP) applies to the JVS service area services and to the public services of the Sub-Recipients.

This document has been prepared to conform to the Limited English Proficiency (LEP) requirements identified in the U.S. Department of Transportation’s implementing regulations, and Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency.” This document is also consistent with Title VI of the Civil Rights Act of 1964 and the U.S. Department of Justice’s guidelines on self-assessment, which are contained in the Language Access Assessment and Planning Tool for Federally Conducted and Federally Assisted Programs (May 2011).

JVS uses information obtained in a Four Factor Analysis to determine if the specific language services provided are appropriate. This analysis helps JVS communicate effectively with persons with LEP or low-literacy. The Four Factor Analysis considers the following components:

  • The number or portion of LEP persons eligible to be served or likely to be encountered By JVS in East Orange.
  • The frequency with which LEP persons come into contact with JVS in East Orange.
  • The nature and importance of JVS activities, programs, and services in people’s lives.
  • The resources available to the recipient for LEP outreach, as well as the costs associated with that outreach.

The following details the results of the four-factor analysis for JVS in East Orange, NJ.

English only 180,189 +/-1,697
Spanish 49,357 +/-844
Limited English speaking household 15,939 +/-734
Not a limited English speaking household 33,418 +/-942
Other Indo-European languages 33,112 +/-1,075
Limited English speaking household 8,675 +/-618
Not a limited English speaking household 24,437 +/-885
Asian and Pacific Island languages 8,210 +/-448
Limited English speaking household 1,707 +/-231
Not a limited English speaking household 6,503 +/-421
Other languages 6,877 +/-480
Limited English speaking household 864 +/-209
Not a limited English speaking household 6,013 +/-421

Source U.S. Census Bureau 2010-2014, 5-year American Community Survey. It is noted that this data categorizes Limited English Proficiency as persons who speak English “less than very well” which includes residents who speak English “well”, while LEP is generally considered a person who speaks English “not well” or “not at all”.

Frequency of Use by LEP Populations

Individuals with LEP proficiency inquire about program participation and are affected by services provided by JVS occasionally. Individuals with limited English proficiency may come into contact with JVS by calling the agency telephone number, visiting the facility or using the agency’s website.

The languages most often encountered by JVS East Orange are English and Spanish.

Transportation participants are encouraged to provide feedback during monthly participant meetings. All program participants are asked to provide input and feedback on transportation, along with all other concerns that may arise.

JVS has one handicapped bus that transports disabled individuals and frail, disabled seniors for the purpose of vocational education and training, along with work.

JVS understands that LEP is a barrier to using program services for an individual and, in a broader sense, participating in a fulfilling life. Part of our education-based programs feature ESL classes for individuals that require that type of assistance.

Providing Language Assistance for Relevant Programs, Activities and Services

Since JVS has served an émigré population for many years, providing translation for those with LEP is consistent with our overall mission.

Our Participant Manual and all other important documents related to JVS are printed in English and Spanish and provided to all program participants during their initial orientation and as needed at future dates. JVS also has individuals on staff to provide assistance to those participants with limited English proficiency in the following languages:

  • Spanish   
  • Russian  
  • Creole    
  • Yiddish     
  • American Sign Language  
  • Farci

Staff and Training

To ensure that all LEP individuals who rely on the transit services provided by the program, JVS staff is aware of the need to reach out to those individuals and provide information. To ensure that all staff members are aware of this need, staff has received training. This training includes the distribution and review of the Title VI documents (policies, forms, procedures, etc.) by all staff. Acknowledgment of training is documented by the supervisor and kept on file.

Particular attention is given to the training of staff who deal directly with transportation. Staff that receive and respond to passenger requests for service changes, complaints, and other needs shall be trained to directly report information from LEP and low literacy riders to the Rehabilitation Director.

Providing Notice to LEP Individuals

JVS provides a written Participant Manual and other vital documents to its participants in both English and Spanish.

The Title VI documents are also provided to all program participants during their initial intake and as needed or requested in both English and Spanish. If other languages are required, JVS multi-lingual staff provides the necessary translation services for any LEP individuals.

Monitoring, Evaluating and Updating the Plan

JVS will continue to monitor the availability of the Title VI program to all participants, including those individuals with LEP. Evaluation of participant satisfaction surveys, participant meetings and staff contact will provide invaluable information and ensure successful implementation now and in the future. The plan will be reviewed annually or as needed and recommendations for updates and improvements will be incorporated into the plan.

The following will be monitored in the reviews:

  • Statistics kept on LEP and low-literacy Contacts
  • Effectiveness and usages of written translated documents
  • Assessment of the Civil Rights Act Title VI Program

JVS is committed to improving access to its services and programs for LEP and low-literacy individuals.   JVS had determined that there are currently outreach materials for the languages spoken by individuals with Limited English Proficiency in its service area. The current translation of vital documents into Spanish and the access to translation services is sufficient to meet the needs of Spanish speaking participants.   JVS will continue to provide translation of vital documents into other languages as need arises. Furthermore, JVS will continue to provide its monitoring process to ensure accessibility of services and information to the LEP population.