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1 1: orkli>r .l, ( O'\ l\ FC TIO'\S I , I "" I ' Workforce Connections Adinin-010-01 General Policies WIA Administrative Standards Revised: Policy Approved By: WC Executive Director l '\ Policy Adopted on: July 2014 IY-'l~ Purpose: and uib ance for WIA Title I Administrative To establish Workforce Connections (WC) Polic y g Standards. Background: Administered at the Federal Level by the Employment and Training Administration (ETA) in the Department of Labor (DOL), WIA is the largest single source of Federal funding for Workforce development activities . Title I ofWIA seeks to provide universal access to employment and training programs through a nationwide network of one-stop centers and service providers administered through State and Local Workforce Investment Boards (LWIBs). WIA Title I establishes a governance and operations infrastructure, and sets performance and accountability standards for all Title I funded programs.)

2 Policy: All recipients and sub-recipients, including contractors and service providers, receiving Workforce Investment Act (WIA) funds must operate under WIA Title rlaws and regulations that prohibit certain activities . activities in any of the prohibited areas will be cause for the imposition of sanctions and possible de-obligation of funds. This policy applies to all Workforce Connections Service Providers providing WIA Title I services to adults, dislocated workers, youth, and the One-Stop operators. Reference: [PL 105-220 Sec. 195 (5)] [PL 105-220 Sec. 195 (6)] [PL 105-220 Sec. 181 (b)] [PL 105-220 Sec. 181 (b) (c)] [PL 105-220 Sec. 188 (a) (3)][TEGL 1-05] [PL 105-220 Sec. 181 (b) (2) (B)][PL 105-220 Sec. 195 (2)] [PL 105-220 Sec. 181 (b) (7)] [PL 105-220 Sec. 181 (d) (1) (2)] [PL 105-220 Sec. 181 (e)] [PL 105-220 Sec.]

3 181; Title 29 of the Code of Federal Regulations Part 37] [Title 29 of the Code of Federal Regulations Part 34] [PL 105-220 Sec. 184 (a) (2) (3)] [Title 20 of the code of Federal Regulations Part , 264, 266] Action: Upon acknowledgement of this policy, it is the service providers' responsibility to ensure and observe all staff is informed of this policy and to create an internal process to ensure accountability. Workforce Connections Policy Admin-010-01 11 WC General Policies Workforce Connections is an equal opportunity employer/program. I t ~ 1 I 1 ' -Addendum-1 I. Conflict of Interest A. Each grantee and sub-grantee shall maintain written standards of conduct governing the performance of persons engaged in the award and administration ofWIA Title I contracts, agreements, and the procuring of goods or services with Title I funds.

4 B. Service provider shall take every reasonable course of action in order to maintain the integrity of its program and will avoid any favoritism and questionable or improper conduct. Service provider shall administer its program in an impartial manner, free from efforts to gain personal, financial, or political gain. Service provider, its executive staff and employees, will avoid all situations which give rise to a suggestion that any decision was influenced by prejudice, bias, special interest, or personal gain. C. Each grantee and sub-grantee shall avoid organizational conflicts of interest. No employee, officer or agent of the grantee or sub-grantee shall participate in the selection, award or administration of a contract supported by Federal funds if a conflict of interest, real or apparent, would be involved [Title 29 of the Code of Federal Regulations Part (b) (3)].

5 Such a conflict of interest arises when any of the following has a financial or other interest in the firm selected for award: 1. The employee, office or agent; 2. Any member-of-his/her immediate-family-to-thethird-degree-of-c onsanguinity; "Third degree of consanguinity" is defined as: a) An immediate family member who includes spouse, father, mother, brother, sister, daughter, son, brother-in-law, sister-in-law, daughter-in-law, mother-in-law, father-in-law, aunt, uncle, niece, nephew, grandson, granddaughter, grandparents, stepparent, and stepchild. b) Also included with this definition is any person who has lived with a Workforce Connections' employee for the previous year. 3. His or her partner; or 4. An organization which employs, or is about to employ, any of the above. D. The grantee's or sub-grantee's officers, employees or agents will neither solicit nor accept gratuities, favors or anything of monetary value from contractors, potential contractors, or parties to sub-agreements.

6 E. To the extent permitted by State or local law or regulation, such standards of conduct will provide penalties, sanctions, or other disciplinary actions for violations of such standards by the awarding agency's officers, employees or agents, or by contractors or their agents. Workforce Connections Policy Admin-010-01 WC General Policies Workforce Connections is an equal opportunity employer/program. 1: ' ( O'\ NF( TIC ' S I .. lo I II. lobbying activities [Title 29 of the Code of Federal Regulations part 93] Addendum-1 Continuation A. No funds provided under Title I of WIA may be used in any way to attempt to influence in any manner: 1. A member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification, of any Federal contract, grant, loan, or cooperative agreement; or 2.))

7 State or local legislators to favor or oppose any legislation or appropriation by such legislators. Communications and consultation with State and local legislators for the purpose of providing information such as on matters necessary to provide compliance with the Workforce Investment Act shall not be considered lobbying . B. If any funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with a Federal contract, grant, loan, or cooperative agreement, the undersigned shall complete and submit Standard Form-LLL, "Disclosure Form to Report lobbying ", in accordance with-its instructions. C. Certification regarding lobbying language must be included in all award documents for all sub-awards at all tiers (including sub-contractors, provider agreements, and contracts under grants, loans, and cooperative agreements) and that all sub-recipients shall certify and disclose accordingly.

8 III. Political activities or Patronage A. No recipient or sub-recipient may select, retain, or promote staff or participants based on that individual's political affiliation or beliefs. The selection or advancement of employees as a reward for political services or as a form of political patronage, whether or not the political service or patronage is partisan in nature, is prohibited. B. There shall be no selection of service providers or contractors based on political patronage or affiliation. C. There shall be no financial assistance for any program under Title I of WIA that involves political activities . D. No participant may be employed or out-stationed in positions involving political activities in the offices. E. No recipient, sub-recipient or employee may engage in partisan or nonpartisan political activities during hours for which the individual is paid with WIA funds.

9 Workforce Connections Policy Admin-010-01 11 WC General Policies Workforce Connections is an equal opportunity employer/program. I I I I I Ml Cl> i ' (\$ ! ! I I I I I I I I j !: ()/",~_/Ol'CL' ( '()" i\' E( "Tl 0 :\ s 1 11 . I '-I ' I i IV. Kickbacks/Fees Addendum-1 Continuation A. It is prohibited: 1) to provide, attempt to provide, or offer to provide any kickback; and to solicit, accept, or attempt to accept any kickback [41 531 B. No person or organization may charge an individual a fee for the placement or referral of the individual in or to a workforce investment activity under Title I ofWIA [PL 105-220 Sec. 195 (5)]. Nothing in this section shall be interpreted as prohibiting the recipient or sub-recipient from entering into an agreement for the purpose of obtaining outreach, recruitment and/or intake services, and placement of participants into unsubsidized employment as part of its approved plan, provided the individuals served are not charged a fee.))]

10 V. Nepotism Nepotism is an inequitable practice that occurs when hiring or delivery of program services is based on personal connections. A. No individual may receive WIA services directly from any staff that has a personal relationship or is a member of that person's immediate family to the third degree of consanguinity. "Third-degree of consanguinity" is defined as: 1. An immediate family member who includes spouse, father, mother, brother, sister, daughter, son, brother-in-law, sister-in-law, daughter-in-law, mother-in-law, father-in-law, aunt, uncle, niece, nephew, grandson, granddaughter, grandparents, stepparent, and stepchild. 2. Also included with this definition is any person who has lived with a Workforce Connections' employee for the previous year. When relationships such as those listed above or others that may be perceived as a relationship exist, service providers must use prudent judgment and refer the individual to other staff or another service provider as appropriate.