IXP3 Equal Employment Opportunity EEO Policy

Equal Employment Opportunity Statement

The stakeholders of IxP3 have enjoyed over twenty years of successful business ventures. They attribute their business success to the significant contribution of their staff. Their experience with the IxP3 team is consistent with their experience with other teams in their previous ventures. They have, and continue, to enjoy the assistance of a broad range of staff without regard to any personal features, preferences or capability. Indeed, the largest differentiating aspect of our staff is a single minded willingness to succeed as professionals and as individuals in the world community. Our staff belief in themselves as individuals and in their capacity to interact effectively with all people is what sets IxP3 employment policy apart from our competitors. IxP3 can help our staff achieve extraordinary success but we believe that only by employing people who deeply believe in EEO will we exceed our customers expectations and meet our long term goals.

IxP3 complies with the appropriate legislation and this is reflected in IxP3's EEO policy in all our processes. The EEO policy has been implemented and is complemented by the IxP3 Privacy Policy. The following principles apply to our internal processes :

• We expect all of our staff to comply with our EEO policies
• We apply these EEO principles in all our internal employment practices including recruitment, training, promotion, disciplining and all other terms and conditions of employment
• Our advertising reflects equality in the opportunity
• We seek specific evidence and data during the selection process
• Whenever appropriate we attempt to independently validate the evidence and data we collect
• Competency based techniques are used to assess the qualities being sought
• Individual bias and prejudicial tendencies are minimised through training and double checking
• Worlds best practice line of business software and technology ensures that information captured is recorded consistently
• The accuracy of recorded information is maintained by recording information as soon as possible after the interview

The role of EEO in Recruitment

In order to maximise client and candidate outcomes, IxP3 has implemented a regime of ongoing training and training updates with regards to EEO. This training specifically results in our consultants not asking inappropriate questions about, for example, date of birth and marital status.

We regard discrimination as the act of treating people less favorably or prejudicially because of :

• their past or present status or private life in the same or similar circumstances
• characteristics which apply, or are thought to apply, to persons of a particular status or private life
• the imposition of a condition which is not reasonable in the circumstances

From the perspective of employment and recruitment, discrimination relates to:

• Who is considered for an employment opportunity
• Who is offered employment
• Denying a person access to training and development opportunities
• Denial of promotion or transfer
• Dismissal
• Any other detriment

IxP3 will not discriminate against any person on the grounds of status or private life by denying our services or by prejudicially dealing with any person.

How Discrimination is Identified

Essentially, discrimination is individually determined. It does not matter whether the person causing the discrimination acted intentionally or not, it is the impact of that persons behaviour that is the key. This means that any person who is discriminated against as a result of subconscious stereotyping and prejudices, has the same rights of redress as a person who is discriminated against intentionally.

A single, isolated incident of sexual harassment is sufficient to constitute discrimination. It is not necessary for a disadvantaged person to prove that he or she was disadvantaged by the action. All that is required is that he or she felt offended, humiliated or intimidated and that a reasonable person would have expected that reaction given their conduct.

Legislative and Political Environment

The recent introduction of the Privacy Amendment Act serves to reinforce EEO policy by giving ordinary people control over all information which is kept on them. In fact, it is now possible to request that copies of personal records be provided and even destroyed if so requested by an individual.

IXP3 EQUAL EMPLOYMENT OPPORTUNITY STATEMENT

Statement of EEO Compliance

IxP3 complies with all legislation relating to unlawful discrimination in employment, and affirmative action regulations.

Specifically:

• Human Rights and Equal Opportunity Commission Act 1986
• Affirmative Action (Equal Employment Opportunity for Women) Act 1986
• Disability Discrimination Act 1992
• Racial Discrimination Act 1975
• Sex Discrimination Act 1984
• Equal Opportunity Act 1984 (Victoria)

IxP3 Policy Statement

Except where a certain characteristic is an appropriate and bone fide occupational qualification, the Company does not condone, and regards as unfair, all forms of unlawful discrimination or vilification including that which relates to:

• age
• race
• colour
• national or ethnic origin
• descent
• nationality
• gender
• marital status
• state of being a parent, childless or defacto
• pregnancy
• sexual preference
• sex
• criminal record
• medical record and/or intellectual disability
• psychiatric disability
• religious and/or political beliefs
• family responsibilities
• trade union activity

All our staff are held accountable in order to prevent unlawful discrimination.

In order to maximise the client outcome we ensure that for all assignments, the position is marketed to as many applicants as possible until we have developed a viable short list. The breadth of the initial marketing of the position ensures that we comply with our EEO responsibilities.

The alignment of staff output with our organisational goals form the basis for performance assessment, training needs and development opportunities as well as promotions.

Training and education programs for staff are mapped to fit the IxP3 organisational goals. They are designed to maximise the performance of IxP3 staff in a competitive and changing global environment.

Each IxP3 director or licensee is required to develop and execute a business plan which gives effect to this policy as well as meeting the requirements of legislation and regulations on affirmative action.

All IxP3 staff are required to immediately advise their management and executives of possible breaches of this policy in order to create and execute an action plan with the greatest sense of urgency.

PROCEDURE FOR DEALING WITH BREACHES OF EEO POLICY

Statement of Purpose

To document the process of managing EEO breaches so that IxP3 staff understand what behaviour is expected of them with regard to EEO policy.

Aim

The aim of this disciplinary policy is to:

• Provide guidelines for expected behaviour of employees with regard to EEO policy.
• Motivate IxP3 staff to meet and exceed EEO policy standards whenever possible.
• Detail the procedure for dealing with breaches of EEO policy.
• Create consistent procedures across all IxP3 businesses for dealing with EEO policy breaches.

Procedure

Any staff who believe they are being unfairly discriminated against must immediately raise the matter with their immediate manager or a director.

The employee may request a formal or informal investigation of the matter, at their own discretion. The manager or director will determine the nature of the complaint and the outcomes the desired by the complainant. In all cases, if the manager or director feels that it is warranted, the company has the discretion to start a formal investigation.

If either the employee or the company decides to start a formal investigation then the managers and directors must consult with each other on the process to be used.

During the investigation, the following guidelines must be followed:

• treat the complaint seriously, with prompt, confidential attention
• identify complainant’s wishes as to outcome
• explain and consult with employee regarding next action

If investigation is not requested and does not appear warranted:

• act promptly, while the issue is current
• maintain confidentiality through restricted discussion
• ensure a manager or director is advised ASAP
• keep notes of key points

If investigation is agreed:

• always involve a director if a director is not already aware
• interview all directly concerned, separately
• interview witnesses, separately
• keep separate and secure written records of investigation (not on personnel file)
• The only data to be recorded on personnel files are the fact that the accusation was made, the conclusion of any investigation, and any action taken which concerns the persons involved. Records of investigation are to include at least the names and work locations of those involved, the relationship between them, and information collected regarding the complaint. This data must be maintained for three years.
• no assumptions of guilt are to be made
• confidentiality, wherever possible, minimise disclosure
• determine appropriate action, generally by consultation with the complainant and possibly the person accused
  • outcomes as they affect the complainant should be discussed with the complainant to ensure that needs are met.
  • check to ensure the outcome meets the needs of the complainant and the Company
  • the manager or director involved is responsible for ensuring that any relevant action is initiated.

All the involved managers and directors are responsible for conducting a review of complaints. The outcome of any actions must also be reviewed in order to seek improvements in workplace behaviours and resolution processes. Confidentiality must be maintained as effectively as possible during these processes.