The Goal of Equal Employment Opportunity: No Victims.*

In an effort to improve Human Resource efficiencies and increase focus on EEO, the County has centralized its Human Resource functions in the new HRSD. Response: Agrees with the finding. On June 26, 2012, the Board of Supervisors approved the commencement of planning efforts to recentralize countywide human resources (HR) services and directed the Office of Performance Audit Director to assist the HR Director in developing a reorganization and centralization proposal. In November 2012, the Board subsequently approved the reorganization plan with implementation beginning in December 2012 and continuing in phases over an 18-month period. The primary goals of the recentralization are to: Ensure compliance, standardization, and uniform application of federal, state, and local regulations, policies and procedures to reduce the County's risk exposure. As one part of this effort, in February 2013, the County hired a new Equal Employment Opportunity (EEO) Access Manager to oversee all EEO functions and has allocated funding for an additional position (Staff Specialist) to support the EEO Office. It is anticipated that the EEO Staff Specialist will be in place by September 2013. It is the responsibility of the EEO Access Office to ensure compliance, standardization and uniform application of all federal and state EEO laws, as well as, uniform application of the County's EEO and Anti-Harassment Policy. The EEO Manager COUNTY OF ORANGE Responses to Findings and Recommendations 2012-13 Grand Jury Report entitled "The Goal of Equal Employment Opportunity: NO VICTIMS" along with the Compliance Oversight Committee will review all EEO complaints and monitor the investigations of those complaints. Additionally, the EEO Access Office will provide guidance on Americans with Disabilities Act (ADA) matters; and, to the extent possible participate in interactive process meetings and monitor the return to work of employee's currently on leave of absence. Furthermore, the recentralization of countywide HRS functions allows for consistency with EEO Policy to reduce the risk of noncompliance and liability.

The County has implemented a Compliance Oversight Committee (COC) to review all EEO complaints in the County. Response: Agrees with the finding. In mid-2012, County Counsel, the Human Resources Director, and the Internal Audit Director (supported by the Board of Supervisors and the County Executive Officer) established the Compliance Oversight Committee (COC) to address an increase in the number of EEO complaints occurring from a high profile case. At the behest of the Board, the COC operates based upon formal administrative procedures defining the COC's role in the investigation and adjudication of discrimination, harassment, and retaliation complaints alleging a violation of County EEO and Anti-Harassment Policy and Procedures. In August 2013, the establishment of the COC was reaffirmed under the authority of the CEO and the formal administrative procedures referenced above. Additionally, the Ad- Hoc Litigation Subcommittee, composed of Chairman Nelson and Supervisor Spitzer, proposed additional procedures to add to and enhance the formal review process to ensure that proactive steps are taken within the County to investigate and report on claims and litigation. The enhanced procedures are now being formally documented and will be communicated to department heads within the next 30 to 60 days to ensure Countywide compliance with the procedures, and to ensure that all County employees enjoy a work environment free of unlawful harassment, discrimination, and retaliation, and that allegations are promptly and thoroughly investigated and addressed. COUNTY OF ORANGE Responses to Findings and Recommendations 2012-13 Grand Jury Report entitled "The Goal of Equal Employment Opportunity: NO VICTIMS"

Complaint ratios between OC cities and the County of Orange are similar; but differences in how previous complaints were handled in the County led to major problems. Response: Disagrees partially with the finding. The EEO Access Office has been responsible for the investigation of all EEO related complaints since 1975 when the Affirmative Action Office was approved by the Board of Supervisors. Since then, the office has investigated a number of complaints with few complications. In the overwhelming majority of cases the County has processed complaints appropriately, treated complainants with respect and dignity, and followed established documented procedures and policies relating to complaints of discrimination and harassment. This includes taking appropriate remedial action against those who violate EEO policy. Supervisory personnel were trained to identify and report instances of harassment and discrimination, and matters were investigated quickly and thoroughly. In one instance, inconsistencies in how existing policy was interpreted and carried out came to light during a recent, high-profile case. Once notified, the Board took swift action to correct the deficiencies that led to this situation, including: Instituting a Board Subcommittee on EEO and Discrimination Investigations • Increasing staff in the EEO Access Office • Directing the review and subsequent approval of revisions to the EEO Discrimination and Anti-Harassment Policy Support for reestablishing the Compliance Oversight Committee (COC) • Establishing countywide procedures for the investigation and adjudication of complaints Providing training of all supervisory personnel regarding the prevention of . discrimination, harassment, and retaliation Contracting with an online vendor to provide county-wide EEO training to all non- supervisory employees Establishing an EEO Hotline to allow for anonymous complaints . COUNTY OF ORANGE Responses to Findings and Recommendations 2012-13 Grand Jury Report entitled "The Goal of Equal Employment Opportunity: NO VICTIMS"

The County and several cities do not offer, or provide limited, training in harassment, discrimination, and retaliation, particularly for line staff. At this time, although line staff training is not required, all staff benefit from EEO training. Agrees with the finding. Response: The Board of Supervisors, recognizing that all staff would benefit from EEO training, directed that the County provide EEO training for the County's non- management/supervisory staff (approximately 13,500 employees). The County is currently negotiating for services and it is anticipated that online training will commence during the last quarter of 2013. County Combined Response to Grand Jury Recommendations