Far West Helping Foundation Corp (FWHFC)

Policy Overview

Far West Helping Foundation Corp (FWHFC) is committed to full compliance with all applicable federal, state, and local civil rights laws, grant requirements, funding conditions, and contractual obligations. This Non-Discrimination and Equal Opportunity Policy establishes FWHFC’s commitment to fair treatment, equal access, respectful service delivery, accessibility, and inclusive participation in all programs, services, employment practices, volunteer activities, partnerships, procurement activities, and federally, state, local, privately, or corporately funded programs.

This policy complies with all applicable federal civil rights laws, including but not limited to Title VI of the Civil Rights Act of 1964, Title VII, the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, and all applicable state and local non-discrimination laws.

FWHFC strictly prohibits discrimination, harassment, retaliation, intimidation, exclusion, unequal treatment, denial of benefits, or denial of reasonable accommodation in any form. This policy applies to all employees, board members, officers, volunteers, applicants, clients, program participants, contractors, vendors, consultants, subrecipients, partner agencies, and any individual or entity working with or on behalf of FWHFC.

1. Protected Classes

No person shall be excluded from participation in, denied benefits of, or subjected to discrimination based on:

• Race, color, or national origin
• Sex, pregnancy, gender identity, gender expression, or sexual orientation
• Religion, creed, or belief
• Age
• Disability or perceived disability
• Genetic information
• Marital, family, parental, or household status
• Veteran, military, or uniformed service status
• Citizenship or immigration-related status where protected by law
• Limited English Proficiency or primary language
• Income status, source of income, or public assistance status where protected
• Any other status protected by federal, state, county, city, grant, contract, or funding requirements

2. Legal and Funding Compliance

This policy is intended to support compliance with applicable civil rights, equal opportunity, accessibility, employment, housing, grant, and contract standards, including:

• Title VI of the Civil Rights Act of 1964
• Title VII of the Civil Rights Act of 1964
• Americans with Disabilities Act (ADA)
• Section 504 of the Rehabilitation Act of 1973
• Fair Housing Act
• Age Discrimination Act of 1975
• Executive Order 13166 regarding Limited English Proficiency
• Equal Employment Opportunity requirements
• 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
• Florida Civil Rights Act and applicable state/local civil rights laws
• Applicable HUD, FEMA, DOJ, HHS, DOT, USDA, state, county, municipal, foundation, corporate, and private funding requirements

3. Scope of Policy

This policy applies to all FWHFC operations, including but not limited to:

• Housing assistance, housing counseling, and housing stability programs
• Food, nutrition, clothing, and emergency assistance services
• Disaster preparedness, response, recovery, and mitigation activities
• Transportation programs and community mobility services
• Health, wellness, victim support, and family support programs
• Youth, education, workforce, mentoring, and community development programs
• Employment, hiring, promotion, discipline, training, compensation, and termination
• Volunteer recruitment, placement, supervision, and removal
• Vendor, contractor, consultant, partner, and subrecipient relationships
• Public outreach, communications, referrals, applications, and intake processes

4. Equal Access to Programs and Services

FWHFC provides programs and services based on eligibility, availability of resources, documented need, program requirements, and lawful funding criteria. Eligibility rules must be applied consistently and fairly.

• Individuals shall not be denied services based on protected status.
• Staff and volunteers must treat applicants and participants with dignity and respect.
• Program decisions must be documented and based on neutral, lawful, and consistent criteria.
• Referrals must be provided fairly when FWHFC cannot directly meet a need.
• Disaster and emergency services must be offered without discrimination and with reasonable efforts to reach underserved populations.

5. Employment, Volunteer, and Board Equal Opportunity

FWHFC provides equal opportunity in recruitment, hiring, selection, placement, promotion, training, discipline, compensation, termination, volunteer service, and board participation.

• Employment and volunteer decisions must be based on qualifications, role requirements, conduct, performance, availability, and organizational need.
• Harassment, discriminatory comments, intimidation, or hostile conduct are prohibited.
• Reasonable accommodations shall be considered for qualified individuals with disabilities.
• Retaliation for reporting discrimination or participating in a complaint process is prohibited.

6. Accessibility and Reasonable Accommodation

FWHFC will make reasonable efforts to ensure that individuals with disabilities have meaningful access to programs, services, employment, volunteer opportunities, and public communications.

• Reasonable accommodations may be requested by applicants, clients, employees, volunteers, or program participants.
• Requests will be reviewed promptly and handled respectfully.
• FWHFC may provide alternate formats, modified procedures, accessible communication, or other reasonable adjustments when required.
• Accommodation decisions will be documented when appropriate for compliance and audit purposes.

7. Limited English Proficiency and Language Access

FWHFC recognizes the importance of meaningful access for individuals with Limited English Proficiency. When required or feasible, FWHFC will take reasonable steps to provide language assistance.

• Language assistance may include interpretation, translated materials, bilingual staff support, or referral support.
• Individuals shall not be denied services because they speak another language.
• Program staff should document language access needs when relevant to service delivery.

8. Prohibited Conduct

FWHFC prohibits conduct that violates this policy, including:

• Discrimination, exclusion, or unequal treatment
• Harassment, intimidation, threats, slurs, offensive jokes, or hostile conduct
• Sexual harassment or unwelcome sexual conduct
• Retaliation against any person who reports a concern or participates in an investigation
• Denial of reasonable accommodation when required by law
• Unequal application of eligibility rules, referrals, discipline, or benefits
• Discriminatory conduct by employees, volunteers, contractors, vendors, subrecipients, or partners

9. Contractor, Vendor, Partner, and Subrecipient Compliance

All contractors, vendors, consultants, subrecipients, and partner agencies working with or on behalf of FWHFC are expected to comply with applicable non-discrimination, equal opportunity, accessibility, and civil rights requirements.

• Contracts and agreements may include non-discrimination provisions.
• Subrecipients may be required to follow applicable grant and civil rights requirements.
• FWHFC may monitor compliance when required by grant, contract, or funding source.
• Violations may result in corrective action, termination, reporting, or other remedies permitted by law or agreement.

10. Complaint Procedure

Any applicant, client, employee, volunteer, contractor, partner, or community member who believes they experienced discrimination, harassment, retaliation, denial of access, or unequal treatment may file a complaint with FWHFC.

• Complaints may be submitted verbally or in writing.
• Complaints should be submitted as soon as possible, preferably within 180 days of the incident.
• FWHFC will acknowledge, review, and investigate complaints fairly and promptly.
• Confidentiality will be maintained to the greatest extent possible.
• Corrective action will be taken when a violation is confirmed.
• FWHFC will maintain complaint records for compliance, monitoring, and audit purposes.

11. External Complaint Options

Individuals may also file complaints with applicable external agencies depending on the program, service, employment matter, funding source, or legal issue involved.

• U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity
• U.S. Department of Justice, Civil Rights Division
• U.S. Equal Employment Opportunity Commission
• Florida Commission on Human Relations
• Applicable federal, state, county, municipal, or funding-agency civil rights offices

12. Non-Retaliation

FWHFC strictly prohibits retaliation against any person who reports discrimination, requests accommodation, files a complaint, assists another person, participates in an investigation, or exercises civil rights protections.

Retaliation may result in corrective action, disciplinary action, removal from duties, contract remedies, or other appropriate action.

13. Training, Communication, and Public Notice

FWHFC will communicate this policy to staff, volunteers, leadership, and relevant partners. Training and awareness activities may include:

• New employee and volunteer orientation
• Annual civil rights and non-discrimination training
• Program-specific training for funded projects
• Posting public notice on the FWHFC website
• Maintaining training records and acknowledgments when required

14. Recordkeeping and Audit Readiness

FWHFC will maintain records necessary to demonstrate compliance with this policy and applicable funding requirements.

• Complaint records and resolutions
• Accommodation requests and responses
• Language access documentation when applicable
• Training records and acknowledgments
• Contractor, vendor, partner, and subrecipient compliance documentation
• Policy review and approval records

15. Enforcement and Corrective Action

Violations of this policy may result in corrective action. Corrective action may include counseling, training, written warning, reassignment, suspension, removal from volunteer service, termination of employment, contract termination, referral to external authorities, or other remedies permitted by law or agreement.

16. Annual Review and Updates

This policy will be reviewed at least annually and updated as needed to remain aligned with federal, state, local, grant, contract, corporate, foundation, and private funding requirements.

17. Adoption and Approval

This policy affirms FWHFC’s commitment to equal opportunity, civil rights compliance, accessibility, fair treatment, ethical service delivery, and readiness for public and private funding compliance.

Approved By: Clebert Merat, Chief Executive Officer
Board Chairperson: ___________________________
Board Approval Date: ___________________________
Effective Date: ___________________________
Review Cycle: Annual, or as required by law, grant, regulation, contract, or organizational need.

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