As part of our on-going review and updating of our Cooperative Policies, the Board addressed several 100 (General) Series policies at its Aug. 3 meeting. In working with our outside legal counsel, the board approved the retirement of:
- Policy 116 – Code of Conduct Whistleblower
- Policy 918 – Non-Discrimination
- Policy 910 – Policy Against Harassment including Sexual Harassment
The Equal Employment Opportunity Commission (EEOC) defines harassment as a form of employment discrimination. Thus, Policies 918 and 910 were combined and replaced with SCEC BD POL 135 Discrimination and Harassment.
In retiring Policy 116 – Code of Conduct Whistle Blower, the board voted to replace it with an expanded Business Ethics policy (SCEC BD POL 133 Business Ethics). The expanded business ethics policy outlines the acceptable and unacceptable behavior for employees and directors.
In revamping the code of conduct whistleblower, discrimination and harassment policies, the reporting of suspected violations to these topics was removed from these three policies and incorporated into a new policy (SCEC BD POL 134 Reporting and Investigation) covering the reporting and investigation of potential violations of the two new policies on business ethics and discrimination and harassment. The most significant change to the reporting and investigation of potential violations was the addition of an independent third-party hotline available to employees who might not be comfortable reporting potential violations to the management team or the Board Chairman. This provides another avenue to raise potential concerns to an outside party who is experienced in performing these types of investigations.
In addition to the new SCEC BD POL 134 Reporting and Investigation policy, two new reporting forms will be utilized: One for general reporting of potential violations of the business ethics policy and a second form containing the necessary information required by federal law for reporting and investigating specific allegations of discrimination or harassment.
The board also voted to retire existing Policy 120 Non-Discrimination Statement. While it is important to post and abide the statement, it does not meet the criteria for inclusion as a policy. SCEC is required to abide by federal laws, state laws and its bylaws and thus they do not need to be restated as cooperative policies.
The board chose to delay the discussion on retaining an outside consultant to oversee the separation of the Rate Policies (Series 300 Policies) into a tariff book until a future board meeting. The board reviewed Policy 310 – Controlled Water Heater and decided not to alter at this time. Minor administrative changes to the policy will be reviewed in August to clarify the control strategies for different sized water heaters and to incorporate the availability of a 100-plus gallon water heater we now offer to members. The clarifications will not impact existing program participants.