EQUAL EMPLOYMENT OPPORTUNITY POLICY
I. GENERAL POLICY
It will be our policy to provide equal employment opportunity to all qualified individuals without regard to race, color, national origin or sex in all personnel actions including recruitment, evaluation, selection, promotion, compensation, training and termination.
It will also be our policy to promote the realization of equal employment opportunity through a positive, continuing program of specific practices designed to ensure the full realization of equal employment opportunity without regard to race, color, national origin or sex.
To make this policy effective, and to ensure conformance with the Rules and Regulations of the Federal Communications Commission, we have adopted an Equal Employment Opportunity Program which includes the following elements.
II. RESPONSIBILITY FOR IMPLEMENTATION
John Anthony Holman, President and General Manager, will be responsible for the administration and implementation of our Equal Employment Opportunity Program. It will also be the responsibility of all persons making employment decisions with respect to the recruitment, evaluation, selection, promotion, compensation, training and termination of employees to ensure that our policy and program is adhered to and that no person is discriminated against in employment because of race, color, national origin or sex.
III. POLICY DISSEMINATION
To ensure that all members of the staff are cognizant of our equal employment opportunity policy and their individual responsibilities in carrying out this policy, the following communication efforts will be made:
The station's employment application forms will contain a notice informing prospective employees that discrimination because of race, color, national origin or sex is prohibited and that they may notify the appropriate local, State or Federal agency if they believe they have been the victims of discrimination.
Appropriate notices will be posted on company premises informing applicants and employees that the station is an Equal Opportunity Employer and of their right to notify an appropriate local, State or Federal agency if they believe they have been the victims of discrimination.
Covenant Network is committed to the following recruitment procedures:
We will attempt to maintain systematic communication, with minority and women organizations to encourage the referral of qualified minority and female applicants. This will include local chapter of the NAACP and the St. Louis Hispanic Chamber of Commerce.
In addition to organizations, which specialize in minority and women candidates, we would also deal with employment services, including state employment agencies, which refer job candidates without regard to their race, color, national origin or sex. Examples of such agencies are the Missouri Division of Workforce Development and the Illinois Department of Employment Security
When we recruit prospective employees from educational institutions such recruitment efforts would include area schools and colleges with significant minority and female enrollments. These include: St. Louis University; University of Missouri-St. Louis; Fontbonne University; and Lincoln University of Missouri.
When utilizing media for recruitment purposes, help-wanted advertisements would always include a notice that we are an Equal Opportunity Employer and contain no indications, either explicit or implied, or a preference for one sex over another, subject to the Religious Broadcaster EEO Policy stated below.
When we place employment advertisements in printed media, some of such advertisements would be placed in media which have significant circulation or are of particular interest of minorities and women. Possible print media that we might consider using in the future would include: a) Broadcasting Magazine, b) NAB Publications, and c) St. Louis Post-Dispatch.
We would also encourage present employees, particularly minority and female employees, to refer minority and female candidates for existing and future job openings.
V. RELIGIOUS BROADCASTER EEO POLICY
Covenant Network was incorporated in the State of Missouri on December 20k 1996 to educate the public about the Gospel of Jesus Christ and the Catholic Church. Covenant Network operates a network of non-commercial educational radio stations and FM Translator Stations located in the states of Missouri, Illinois, Indiana, Louisiana and Oklahoma. Our headquarters are at 4424 Hampton Avenue, St. Louis, Missouri. According to a Policy Statement of the Federal Communications Commission, FCC 98-19, 13 FCC Rcd 6322 (February 25, 1998), the FCC said that it is reasonable to conclude that it is appropriate for all employees of religious broadcasters to share a common commitment to a licensee's basic religious objective and mission. The Commission's action facilitates religious broadcasters' ability to order their internal affairs and eliminates the potential for impermissible governmental interference in the conduct of religious affairs.
The Commission emphasized, however, that this action does not create a blanket exemption from the FCC EEO rule and does not permit religious broadcasters to engage in employment discrimination against women and minorities. When vacancies occur, religious broadcasters will still be required to recruit without limitation on the basis of race, color, national origin or gender from among those who share their religious affiliation or belief.
Previously, the FCC had a limited EEO enforcement exemption for religious broadcasters that only applied the exemption to vacancies involving persons hired to espouse religious views over the air. The Commission said that the new approach would end the need for the current practice of engaging in case-by-case analysis of particular job categories to determine if they involve espousal of the licensee's religious views. The Commission's action responds to concerns by religious broadcasters that its prior approach excessively entangled the government in the affairs of religious entities.
Covenant Network’s stations broadcast a program format consisting of educational and devotional programs designed to teach the Roman Catholic religion to the public and to broadcast Roman Catholic holy Masses as well as devotionals such as the Holy Rosary, the Divine Mercy Chaplet and various litanies.
Therefore, Covenant Network asserts its prerogative to hire believing Roman Catholics to work at its stations. That said, Covenant Network strictly prohibits employment discrimination against women and minorities. When vacancies occur, Covenant Network is committed to recruit without limitation on the basis of race, color, national origin or gender from among those who share their religious affiliation or belief.