Breakout Presenters DISCLAIMER :

1. RAISE THE BAR: HIRE!Concurrent Breakout Session:OFCCP disability regulation trends; data capture and management capacities; employers response actionsPanelists: Stacey Bastone, Jackson Lewis; Sarah Babineau, Compass Metrics, LLC; and Steven Spaeth, National GridFacilitated by: Sean Driscoll, Work Without Limits

2. Breakout Presenters DISCLAIMER: The information provided in this presentation is for educational and informational purposes only. It does not constitute legal advice or legal opinions. The session’s presenters make no claims, promises or guarantees about the accuracy, completeness or adequacy of the information contained herein. Nothing that is provided in this presentation should be used as a substitute for the advice of legal counsel.

3. Breakout Session’s Intent Regarding new and evolving OFCCP disability regulation changes and trends, to provide an informational – • Legal Perspective • Data capture and management Perspective • Employer challenges, goals and desires Perspective

4. A new frontier triggered: voluntary self-identification ‘pre-hire’; qualifying & tracking! • 09/24/13 the U.S. Dept. of Labor of Federal Contract Compliance Programs made changes to the regulations of Section 503 of the Rehabilitation Act of 1973 and the Vietnam Era Veteran’s Readjustment Act (VEVRAA), re: protections of IWDs and PVs Change Highlights: • Provide pre-offer and post-offer invitations to ID • Collect and document data • Document outreach recruitment, track for 3 years • Conduct annual self-assessment of these outreach efforts and document the review • Measure the success of outreach/recruitment against annual hiring benchmarks and utilization goals

5. Why Were The Regulations Revised? • Unemployment rate of working age individuals with disabilities and percentage of working age individuals with disabilities not in the labor force remain significantly higher than for those without disabilities. • Substantial disparity in unemployment rate persists despite years of technological advances making it possible for people with disabilities, sometimes severe, to apply for and successfully perform a broad array of jobs. • Bureau of Labor Statistics data shows: • Workforce participation rate of 31.6% for working age people with disabilities in 2012, compared with 76.5% of working age individuals without such disabilities • Unemployment rate for working age people with disabilities in 2012 was 15%, compared with an unemployment rate of 8% for working age individuals without disabilities. • The median household income for “householders” with a disability in 2011, aged 18 to 64, was $25,420, compared with a median income of $59,411 for households with a householder who did not report a disability.

6. How Were The Regulations Revised? • Focus on accountability for making progress through sustained efforts. • Data collection and metrics are the key to this accountability. • That which gets measured, gets done. • Three focal areas under this framework are: • Improved recruitment; • Increased identification; and • Better retention.

7. Improved Recruitment Self-identification data allows the employer to assess recruitment efforts and revise, if necessary. By requiring retention of records of outreach and recruitment activities for three years, contractors and the OFCCP will be able to better evaluate the effectiveness of efforts in identifying and recruiting qualified individuals with disabilities.

8. Increased Identification • Potential for discrimination claims based on employer’s knowledge of disability. • General mistrust by employees of the forms and the process. • Focus on interactive process and reasonable accommodations based on identified disabilities. • Need for training.

9. Better Retention Increased awareness of individuals with disabilities in the workforce will lead to improvement of employment practices. The required assessment of the employer’s compliance with the 7% disability utilization goal will encourage employer modification of company culture, policies and procedures to establish environment where individuals with disabilities are more likely to stay.

10. Process and Break Points

11. Form In Access Calendar Date & Drop Down List Options

12. Datasheet In Access

13. What are employers asking/needing to do? • Self Identification Efforts • When we ask for the information • What do we do with the information • Employee Resource Group Strategy/Leveraging • Multiple Regions • Community Efforts and Partnerships • Pilot programs • Educating the ‘two-fold’ mindset

14. Self – Identification Efforts When we ask for the information • What part of the hire phase • Multiple opportunities to identify throughout the year • Reasonable Accommodation What do we do with the information • Storage • Tracking efforts What are National Grid’s Struggles • Simply getting our employees to Identify (both veteran and disabled) • Employee Survey results

15. Employee Resource Groups at National Grid • We do not limit our employees to one and only! • Enabling – ERG • Multiple Regions • Community Efforts • Internal Partnerships • External Partnerships

16. E: Educating the ‘two-fold’ mindset Educating the Employer • Educating the manager about hiring someone that may have a disability • Difference between formal disclosure and voluntary self-ID • Reasonable accommodations • Fostering Safe Environment Educating the Employee • Why do we as a business ask for the self-identification and what do we do with the information • Employee Resource Groups playing a role • Leveraging Annual Employee Survey Mechanism

17. Interactive Discussion Between the audience and the panel!

18. Presenter Contact Information: Stacey Bastone, Jackson Lewis stacey.bastone@jacksonlewis.com 631.247.4607 Sarah Babineau, Compass Metrics, LLC sarah.babineau@compassmetrics.com 508.333.1128 Steve Spaeth, National Grid steven.spaeth@nationalgrid.com 315.460.1194 Sean Driscoll, Work Without Limits sean.driscoll@umassmed.edu 508-856-3843