Company policies

Sexual harassment prevention policy

Policy statement

Pacific Medical Training is committed to maintaining a workplace that is free from sexual harassment. Sexual harassment is a violation of the New York State Labor Law and is not tolerated in our organization. This policy applies to all employees, contractors, and visitors.

Definition of sexual harassment

Sexual harassment includes, but is not limited to, unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature. It can occur in various forms, including:

• Verbal: Inappropriate jokes, comments, or requests
• Physical: Unwanted touching or gestures
• Visual: Sharing offensive images or materials

Reporting procedures

Employees who experience or witness sexual harassment should report the incident immediately to their supervisor or the human resources department. All complaints will be taken seriously and investigated promptly.

Investigation

Pacific Medical Training will investigate all reported incidents of sexual harassment in a timely and confidential manner. Appropriate corrective action will be taken if harassment is found to have occurred.

Training

All employees are required to complete annual sexual harassment prevention training. This training will cover:

• Understanding sexual harassment
• Recognizing inappropriate behavior
• Reporting procedures

Training resources

To comply with this requirement, employees must complete the following training:

• New York State sexual harassment prevention training

Commitment to non-retaliation

Pacific Medical Training prohibits retaliation against anyone who reports sexual harassment or participates in an investigation.

Supplier diversity program

Introduction

This supplier diversity program outlines our commitment to promoting the inclusion of certified minority-owned business enterprises (MBEs) and women-owned business enterprises (WBEs), collectively referred to as minority and women-owned business enterprises (MWBEs), in our supply chain. The program is designed to comply with the diversity practices defined in New York state executive law article 15-A, section 310(22), which emphasizes utilizing or mentoring certified MWBEs as subcontractors and suppliers in contracts, as well as entering into partnerships, joint ventures, or similar arrangements with such enterprises.

The program aims to foster non-discrimination, equity, and economic opportunity by integrating MWBEs into our procurement processes. It applies to all procurement activities, with particular emphasis on those related to state contracts exceeding applicable thresholds (e.g., $25,000 for goods and services or $100,000 for construction-related activities, as per section 310(13) and (14)).

Program objectives

1. Increase MWBE utilization: Actively seek and utilize certified MWBEs as suppliers and subcontractors to satisfy diversity requirements in our contracts.
2. Mentoring and capacity building: Provide guidance, training, and resources to help MWBEs grow and succeed in partnership with our company.
3. Partnerships and joint ventures: Encourage collaborations such as joint ventures or strategic alliances with certified MWBEs.
4. Compliance and reporting: Ensure all practices align with state certification requirements and submit utilization plans as needed for state contracts.
5. Continuous improvement: Regularly evaluate and enhance the program to address disparities and promote broader inclusion.

Key definitions

• Certified MWBE: A business enterprise verified as at least 51% owned, operated, and controlled by minority group members or women, pursuant to section 314 of article 15-A. The enterprise must qualify as a small business (e.g., no more than 300 employees) and meet net worth thresholds (not exceeding $15 million, adjusted for inflation).
• Minority group member: Individuals who are Black, Hispanic, Asian, American Indian, Alaskan Native, or Native Hawaiian, as defined in section 310(8).
• Utilization plan: A document submitted with contract bids identifying MWBEs to be used, including their names, addresses, contact information, and scope of work.
• Diversity practices: Policies and actions related to MWBE involvement as suppliers, subcontractors, or partners, in line with section 310(22).

Program components

1. Leadership and governance

• Diversity officer: A designated supplier diversity officer will oversee the program, reporting directly to senior leadership.
• Diversity committee: A cross-functional team including procurement, legal, and operations representatives will meet quarterly to review progress and set goals.
• Policy integration: Supplier diversity will be embedded in all procurement policies, vendor selection criteria, and contract terms.

2. Supplier identification and certification

• Outreach efforts: Our company will view MWBE networking events, trade fairs, and directories maintained by the New York state department of economic development.
• Certification verification: All potential MWBE suppliers must provide proof of certification under section 314. We will verify status through the state’s MWBE directory.
• Database maintenance: View an external database of certified MWBEs, categorized by goods/services offered, to facilitate quick sourcing.

3. Procurement processes

• Inclusive bidding: For all procurements, especially state contracts, we will solicit bids from MWBEs where feasible.
• Goal setting: We recognize MWBE participation goals required by state law and for specific contracts that we pursue.
• Subcontracting requirements: In contracts exceeding $25,000, require prime contractors to submit MWBE utilization plans and report on subcontractor diversity.
• Non-discrimination clause: All supplier contracts will prohibit discrimination and mandate compliance with article 15-A.

4. Mentoring and development

• Mentorship program: Pair certified MWBEs with internal mentors for guidance on bidding, compliance, and business development.
• Training workshops: Refer to workshops on topics such as contract management, financial planning, and technology adoption.
• Financial support: Explore options like prompt payment terms or access to financing resources to support MWBE growth.

5. Partnerships and joint ventures

• Collaboration opportunities: Identify projects suitable for joint ventures, where MWBEs can contribute expertise and share risks/rewards.
• Agreement frameworks: Develop standard templates for partnerships that ensure MWBE control and ownership align with certification criteria.
• Tracking: Monitor and report on the number of joint ventures annually.

6. Monitoring, reporting, and compliance

• Performance metrics: Track key indicators such as MWBE spend percentage, number of certified suppliers, and mentorship outcomes.
• Annual reporting: Submit reports to state agencies as required for contracts, including utilization plans and diversity practice disclosures.
• Audits and reviews: Conduct internal audits annually as required by contracts to ensure compliance.
• Corrective actions: Address any non-compliance through training or process adjustments, with escalation to leadership if needed.

7. Training and awareness

• Employee training: All procurement staff must follow article 15-A requirements.
• Supplier education: Provide resources to suppliers on the benefits of subcontracting with MWBEs.

Implementation timeline

• Year 1: Establish governance, see MWBE databases, and launch outreach efforts.
• Year 2: Integrate into procurement systems and initiate mentoring programs.
• Ongoing: Annual reviews and goal adjustments based on performance and state updates.

Contact information

For questions or to register as a potential MWBE supplier, contact our supplier diversity officer.

This program will be reviewed annually and updated as needed to remain compliant with New York state executive law article 15-A and related regulations. We are committed to fostering an inclusive supply chain that drives economic growth for all.