XVIII. AURA GRIEVANCE POLICY AND PROCEDURES A. POLICY

Revised August 2012

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XVIII. AURA GRIEVANCE POLICY AND PROCEDURES

A. POLICY

In an effort to foster and maintain a productive and respectful workplace, AURA

employees who feel they have a grievance or formal complaint regarding any of its

policies, practices, managers or supervisors have the opportunity to have such

grievances and complaints heard and responded to fairly and promptly. Accordingly, the

procedures under Section B below have been developed to assure timely and equitable

resolution of employee complaints and also to assure that neither shyness nor fear of

reprisal should inhibit any employee seeking a remedy.

Except for communications with or initiated by the complainant, participants in the

grievance process will treat as confidential any information gained during participation.

This includes all aspects of handling, investigating, reviewing and making final decisions

on complaints or grievances.

Unless there are extenuating circumstances, complaints or grievances must be stated

within 15 working days of the occurrence giving rise to the complaint or, if involuntary

termination is involved, within five working days of receipt of notice. If there are

extenuating circumstances, the grievance must be submitted as soon as possible.

For grievance policy applied in Chile refer to B-XXIII - Unique Policies and Procedures

(Chile).

B. GENERAL PROCEDURE GUIDELINES

1. An employee is encouraged to first discuss any complaint or grievance with his or

her immediate supervisor, orally or in writing. The supervisor will endeavor to render

a decision or an interim reply within the next five working days that he or she is

present for duty. An interim reply will include a reason for delay (such as referral to

higher levels of supervision) and an estimate of the time expected to render a

decision.

2. If the employee does not feel he or she can voice a grievance or complaint to his or

her supervisor, or if the employee is not satisfied with the answer received, or if there

has been no reply within the five working days of the issue being presented to the

supervisor, the employee may refer the matter, in writing,

to the next level

supervisor, who will respond as above. This process may be repeated through the

employee’s line of management. All individuals involved will provide copies to the

Human Resources Manager and to supervisors who previously have been included

in the process.

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3. If the employee does not feel he or she can voice a grievance or complaint to his or

her supervisor or line of management, or if the employee is not satisfied with the

answer received, or if there has been no response within the time frames outlined

above, the employee may refer the matter, in writing

, to the Human Resource

Manager. The Human Resources Manager will obtain all available information,

including statements from supervisors and others named or having knowledge of the

matter and will prepare a written summary. Depending on the Center and/or nature

of the matter, the Human Resources Manager may either provide the summary to

Senior Management and/or the Director for resolution of the issue or, at the

discretion of the Director, the Human Resources Manager, may be charged with the

responsibility of determining the resolution. The outcome will be reported to the

employee and to any supervisors who previously have been included in the process

within five working days of obtaining all required information and statements. Advice

of legal counsel will be obtained, if needed.

4. If all other avenues are considered unacceptable or inappropriate based on the

employee’s assessment, the final level of referral will be to the Director. The

grievance or complaint should be made in writing

, to the Director. The Director may

designate a member of management to oversee the investigation of the matter. The

Director may request, if not already completed, that the Human Resources Manager

obtain all available information, including statements from supervisors and others

named or having knowledge of the matter, and prepare a written summary. If the

complaint involves the Human Resources Manager, the Director will designate

another to perform these functions. The Director will notify the complainant and all

others concerned of the final determination on the case within five working days after

receiving the recommendations

5. With the exception of the staff appointed by direct authorization of the AURA Board

of Directors, the Center Director's decision is final. The Board of Directors will be the

final authority on complaints by staff members appointed by authority of the Board of

Directors. Appeals to the Board of Directors will be routed through the President of

AURA.

6. If the grievance is against the Human Resources Manager or Director, the complaint

should be reported to a Corporate Officer.

7. Advice of legal counsel will be obtained, if needed.

8. If at any time the employee feels it necessary, he or she may bypass a level listed

above. This may be the case if:

a. the matter to be discussed personally involves the individual on that supervisory

level; or

b. the employee may be concerned about repercussions with that individual based

on the issue; or

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c. the subject matter is personal and would be embarrassing or inappropriate if

discussed with that individual.

C. RETALIATION

Any employee is encouraged to use this policy when appropriate. No employee will be

subject to reprimand or retaliation as a result of initiating a complaint which is made in

good faith, or as a result of assisting a fellow employee in the grievance process by

providing testimony.

D. CONFIDENTIALITY

Confidentiality will be maintained throughout the investigatory process to the extent

practical. Individuals bringing forth allegations of inappropriate conduct to management,

as well as those who may be involved in the investigation, are expected to maintain

appropriate levels of confidentiality with respect to those allegations among co-workers

at all times.

E. COMPLAINTS INVOLVING IMPROPER ACTIVITIES

There may be times when the nature of the issue or complaint involves such things as

improper activities, ethics violations, discrimination, fraud, etc. and the individual does

not feel that the general grievance/complaint process as the appropriate reporting

mechanism. AURA maintains a confidential resource called IntegrityLine that can be

accessed for the purpose of registering a complaint or concern. Access is available

online and via telephone. Additionally, pursuant to our Federal contracts, our contracting

agencies maintain a confidential fraud hotline which may be used by employees to

report improper acts.

AURA IntegrityLine: https://secure.ethicspoint.com/domain/media/en/gui/32723/index.html

Or Toll Free at 855-257-4106.

F. FALSE COMPLAINTS

A complaint based upon false or inaccurate information will be handled according to its

merits. Individuals making false or misleading statements will be subject to AURA’s

disciplinary process.