What are the rules governing EEO?: Equal employment opportunity (EEO) policy requires all licensees and permittees of commercial and non-commercial radio and television stations to afford the opportunity for employment to all qualified persons and cannot discriminate in hiring because of race, color, religion, national origin or sex. Religious broadcasters may establish religious belief or affiliation as a legitimate qualification for all employment opportunities but cannot otherwise discriminate.
Every broadcast station with five or more full-time employees must have a general program to accomplish the following:
- Define responsibility of each level of management to ensure enforcement of EEO policies and establish a procedure for review and control of management performance.
- Inform employees and recognized employee organizations of the stationís EEO policies and programs and enlist their cooperation.
- Communicate its EEO program and policies to sources of qualified applicants and solicit their recruitment assistance on a continuing basis.
- Conduct a continuing program to exclude all unlawful forms of prejudice or discrimination in its personnel policies, procedures and working conditions.
- Conduct a continuing review of job structure and employment practices and adopt positive recruitment, job design and other measures to ensure EEO compliance at all levels and areas of job opportunities.
- As part of its specific requirements to be followed by all station employment units with five or more full-time employees, the FCC has adopted a three-prong outreach recruitment program which entails extensive record keeping:
- PRONG 1. Recruitment for All Full-Time Vacancies. Widely disseminate information concerning each full-time (30 hours or more per week) job vacancy, except for vacancies filled in exigent circumstances or by internal promotion. This requirement does not apply to part-time or temporary hires.
- PRONG 2. Notification to Community Groups. Notification of all full-time job openings to any organization that distributes employment opportunities to job seekers or refers job seekers to potential employees and has requested to be notified; and
- PRONG 3. Menu Options. Engage in a specified number of activities selected from a menu of options. Complete two (for employment units with five to ten full-time employees or that are located in smaller markets) or four (for employment units with more than ten full-time employees located in larger markets) longer-term recruitment initiatives within a two-year period.
- Record keeping and reporting requirements are also included in the EEO rules. The record keeping requirements include retaining documentation concerning compliance with the three prongs, annually preparing an EEO public file report based on that documentation and placing a copy of that report in the stationís public inspection file. The reporting requirements include the filing of the Broadcast EEO Report (FCC 396) with the stationís renewal application, a Mid-Term Report (FCC 397) and a Model EEO Program Report (FCC 396-A) with an application for initial station construction permit, assignment or transfer of control.