Equal Employment Opportunity (EEO)

This policy is generally required by law.

Sample Policy 1 is a general policy that doesn’t prohibit religious discrimination.

If you are a religious organization, you are generally permitted to give employment preference to those who share your beliefs for positions that have religious functions. In this case, Sample Policy 2 may be more appropriate for your organization.

However, some states and counties have narrowly permitted religious discrimination only for those positions performing a “purely religious function.” As with any policy, it’s important to have it reviewed by  your local attorney. You may be permitted to discriminate on the basis of gender for certain ministry positions. Race cannot generally be used as a basis for discrimination.

As a part of your policy, provide at least two individuals (preferably a male and female) to whom employees can report perceived discrimination.

Your policy should also include a provision stating that individuals will not be punished for filing a complaint that claims an Equal Employment Opportunity (EEO) violation. It is also beneficial to outline reasonable steps your organization will take to protect against retaliation. The policy should affirm that the ministry will investigate all reports diligently and take appropriate disciplinary action against the offender(s), based on the circumstances.

Italicized text in the policy below is variable language.

SAMPLE POLICY 1:
EQUAL EMPLOYMENT OPPORTUNITY

(Name of organization) is an equal opportunity employer. The recruitment and selection process will be based on job-related, objective qualifications, in accordance with the job requirements of the position being filled.

All employees must be able to perform the essential functions of their jobs as set forth in the employee’s individual position description. Reasonable accommodations will be made, in accordance with applicable state and federal laws, to assist employees with disabilities in performing the essential functions of their jobs.

Employees who believe they have been unlawfully discriminated against should report it immediately to (supervisor) or (business administrator).

Guidelines

A reporting employee will not be retaliated against for reporting a violation of this policy. In all reported cases, this organization will take reasonable steps to protect the reporting employee from retaliatory, harassing, or abusive behavior in relation to such reporting. (Provide examples or outline steps here.) This organization will investigate all reports diligently and will take appropriate disciplinary action against the offender(s), based on the circumstances.

SAMPLE POLICY 2:
EQUAL EMPLOYMENT OPPORTUNITY

It is the policy of (name of organization) to grant equal employment opportunity to all qualified persons without regard to race, creed, gender, age, veteran status, disability, or handicap—if such handicap or disability may be accommodated without undue hardship. The recruitment and selection process will be based on job-related, objective qualifications, in accordance with the job requirements of the position being filled. All employees must be able to perform the essential functions of their jobs as set forth in the employee’s individual position description. Reasonable accommodations will be made, in accordance with applicable state and federal law, to assist employees with disabilities in performing the essential functions of their jobs.

(Name of organization) is organized for religious purposes and is substantially controlled and supported by a religious body, (the church denomination). Consequently, (name of organization) enjoys an exemption from the prohibitions contained in Title VII of the Civil Rights Act of 1964 concerning religious discrimination in employment. We further reserve the right to discriminate or designate certain positions based on religion or gender when a bona fide occupational qualification exists. Employees who believe they have been unlawfully discriminated against should report it immediately to (supervisor) or (business administrator).

Guidelines

A reporting employee will not be retaliated against for reporting a violation of this policy. In all reported cases, this organization will take reasonable steps to protect the reporting employee from retaliatory, harassing, or abusive behavior in relation to such reporting. (Provide examples or outline steps here.) This organization will investigate all reports diligently and will take appropriate disciplinary action against the offender(s), based on the circumstances.

This is a sample handbook policy only. Your organization is responsible for compliance with all applicable laws. Accordingly, this document should not be used or adopted by your organization without first being reviewed and approved by a licensed attorney in your area. Brotherhood Mutual assumes no liability in preparation and distribution of this sample document.

Working Together © 2022 Brotherhood Mutual Insurance Company. All rights reserved. www.brotherhoodmutual.com/working-together. Updated 9/2021.