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1992

The Department of Labor’s Glass Ceiling Initiative: A New Approach to an Old Problem

Marshall J. Breger The Catholic University of America, Columbus School of Law

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Part of the Administrative Law Commons, and the Law and Gender Commons

Recommended Citation Marshall J. Breger, The Department of Labor’s Glass Ceiling Initiative: A New Approach to an Old Problem, 43 LAB. L. J. 421 (1992).

This Article is brought to you for free and open access by the Faculty Scholarship at CUA Law Scholarship Repository. It has been accepted for inclusion in Scholarly Articles and Other Contributions by an authorized administrator of CUA Law Scholarship Repository. For more information, please contact [email protected]. The Department of Labor's Glass Ceiling Initiative: A New Approach to an Old Problem By Marshall J. Breger* Mr. Breger is Solicitor of Labor at the U.S. Deportment of Labor.

The concept of a "glass ceiling" is not a of this work force increase. So it is clear new one. At the turn of the century, that to remain competitive corporate Marie Curie almost singlehandedly cre- America will have to pick the best people ated the field of nuclear chemistry and from both the male and female graduates forever changed the course of science and of our best universities. The companies society. But even the ultimate scientific that do not will not be around long. creativity award did not help her to crack Future trends do not address present the barrier of the science establishment. problems, because it has also become clear She received the Nobel Prize but was de- that despite their dramatically increasing nied membership in the French Academie presence in the workplace, there is a des Sciences because of her gender. It was dearth of women and minorities in the only after her second Nobel Prize that the upper ranks of that work force. To put it ali male Academie reluctantly admitted another way, it has been said that the her to the club. The problem that I have problem of the 1970s was bringing women with this story is that a woman should not and minorities into the corporation. The have to win a Nobel Prize to become a problem of the 1980s was keeping them partner in law firm or an executive in a there, and the challenge of the 1990s and corporation. beyond is to remove any artificial barriers impeding their upward mobility. Secre- The development of glass ceiling issues tary of Labor Lynn Martin has made this at the Department of Labor did not re- one of her top priorities. quire a radioactive discovery. Rather, the groundwork was laid several years ago, The Office of Federal Contract Compli- when we commissioned studies by the ance Programs at the Department of La- Hudson Institute on the demographics of bor (OFCCP) recently analyzed data from the American work force in the year 20(X), a sampling of 94 compliance reviews from Those studies, and the reports that fol- Fortune lCXX) companies (representing a lowed, demonstrated that a profound total of 147,179 employees). It found that demographic change is taking place. By while women represented 37,2 percent of the year 2000, the overwhelming majority' all companies' combined work force, only of new entrants into the work force will be 16,9 percent of "officials and managers" minorities, women, and immigrants— working for these companies were women. white males will make up only 15 percent And while minorities represented 15,5

' This anicle is derived from a recent presentation made Mr, Breger before the Association of the Bar of the City of New York, Special Committee on Women in the Profession, Glass Ceiling initiative 421 percent of the companies' work force, only be actual discrimination. It is often a 6 percent of the companies' officials and more subtle form of discrimination, re- managers were minorities.' Furthermore, ferred to as sex stereotyping and recog- these numbers significantly overstate the nized by the Supreme Court in the now percentage of women and minorities at famous case of Price Waterhouse v. Hop- executive-level, decision-making positions, kins, where Justice Brennan stated: "In since the category "officials and manag- the specific context of sex stereotyping, an ers" includes people like the "head" of the employer who acts on the basis of a belief janitorial staff and the "manager" of the that a woman cannot be aggressive, or clerical pool. that she must not be, has acted on the In terms of senior management (i.e., basis of gender .... An employer who those at the level of assistant vice presi- objects to aggressiveness in women but dent and above), the compliance review whose positions require this trait, places pointed out that only 6.6 percent of those women in an intolerable Catch 22: out of in senior management were women and a job if they behave aggressively and out 2.6 percent were minorities. Most of the of a job if they don't." ^ It is precisely this individuals represented in these percent- corporate attitude or culture that the ages, however, are in "velvet ghetto" staff Glass Ceiling Initiative is designed to de- jobs, such as human resources and public tect and eliminate. relations. These types of jobs usually do not put minorities or women on the fast Laying the Groundwork track. So after moving up the ladder a few One of the primary responsibilities of rungs, many women and minorities stop the OFCCP is to enforce Executive Order short and simply mark time. 11246. The Order and its implementing There can, of course, be different rea- regulations prohibit government contrac- sons behind the relative scarcity of women tors and subcontractors from discriminat- and minorities in senior management po- ing against any employee or applicant for sitions. These reasons may include their employment, and it also requires such relatively recent entry into the work contractors to take affirmative action to- force, coupled with the length of time wards ensuring that employees and appli- necessary to reach senior management cants are treated without regard to their levels (estimated to be 20 years for a race, color, religion, sex, or national origin. general manager and 35 years for a CEO); Traditionally, OFCCP's reviews of these the low turnover rate at the management contractors have tended to focus on entry- level; and, to a certain extent, personal level positions. With the Glass Ceiling Ini- choice, if not the—dare I say it— tiative, we have begun to widen the scope "Mommy Track." Yet it cannot be ig- of our attention to include barriers to ad- nored that one of the most pervasive bar- vancement at all ranks of the work force, riers to advancement is cultural attitudes including its senior levels. toward women and minorities. Indeed, a recent poll of Fortune 1000 CEOs found In 1988, OFCCP issued a policy direc- that 81 percent believed "preconceptions tive entitled the Corporate Initiative. by men" were major blocks to women This initiative constituted a major new reaching top levels of management.^ effort to encourage government contrac- tors to increase their efforts in placing Clearly, one reason for the scarcity of women and minorities in senior-level and women and minorities at high levels can executive-level positions. For the first

' "A Report On The Glass Ceiling Initiative", U,S, De- ' 109 US SCt 1775 (1989), 49 EPD fl 38,936, partment of Labor, 1991, at 6, ^ Catalyst, Study of Women in Corporate Management, New York 1990, 422 July, 1992 Labor Law Journal time, corporations with multiple estab- potential managers come to the attention lishments were required to list and set of persons in promotional authority. goals in the headquarters affirmative ac- (2) The Department examined the suc- tion program for all positions filled by cession plan of the corporation which decision makers at the corporate level. So identifies the replacements for key execu- if the manager of the San Francisco plant tives who leave or retire. These plans gen- is not selected in San Francisco but at the erally outline where an employee will be corporate headquarters in New York, the in five years if vacancies occur. So, while position would have to be included in the several individuals may be on the same affirmative action plan at the location rung of the ladder, some are being responsible for making the selection, groomed for advancement while others rather than at the subordinate San Fran- are not. "Glass ceiling" review of succes- cisco establishment. sion plans is perhaps the most significant technical difference from the standard This directive laid the groundwork for compliance review process. Succession The Glass Ceiling Initiative, which began plans are the blueprint for future ad- with nine specially focused "pilot" corpo- vancement at high corporate levels. Scru- rate compliance reviews. In deciding tiny of these plans can result in changes which companies to review, a number of in the future. criteria were employed. First, they had to be among the Fortune 500. Next, they (3) Similarly, the Department ex- had to be from different regions of the amined the complex system of compensa- country and provide a cross-section of in- tion and benefits that are used as dustry groups. Then we compared num- "signals" by the corporate hierarchy to bers within industry groups on the employees who are deemed to be key con- representation of women and minorities in tributors. Because the retention of these certain job categories, flagging and so-called "high potential" employees, or targeting companies that were 20 percent "hi-pots" as they are known in the trade, below the mean of their peers. The compa- is given top priority by corporate officers, nies were randomly selected and repre- we examined the corporate compensation sented seven broad industry groups from structure to determine its application on a five different regions of the country. They nondiscriminatory basis. varied in size from fewer than 8,000 em- (4) The executive recruitment policy of ployees to more than 300,000 employees, the company was examined, particularly with most having international opera- with regard to the use of executive search tions. Three were located in the New York firms. This was done to ascertain whether region. The reviews focused primarily on the company monitored the candidates corporate positions with the titles of Di- sent by the search firm, in order to assure rector or above. itself that it was fulfilling its affirmative action obligations. The pilot reviews differed from stan- dard compliance reviews in their empha- The "Glass Ceiling" Is Confirmed sis and, to some extent, in their technique. For example: The major findings of these pilot re- views were summarized in the Secretary (1) The compliance review team spent of Labor's Glass Ceiling Report, which significant amounts of time not merely was released in August 1991. The findings with the vice-president for human re- in this report confirmed what the studies sources but with other senior executives, had indicated. (1) There was definitely a including the CEO, to understand the his- level beyond which few minorities and tory and particular culture of the corpora- women in each corporation had advanced. tion under review and to determine how (2) We did not find that a hard line ran Glass Ceiling Initiative 423 across each department, but the ceiling overseas experience. In that same com- acted more like an undulating inversion pany, however, there was also a guideline layer, (3) The placement of the barrier precluding women from being given over- varied according to function and salary seas assignments. level. Furthermore, the glass ceiling was at a level lower than anticipated. Indeed, The reviews also indicated that the the pilot reviews revealed much of the companies in the pilot study were not investigative questioning and many areas reviewing their total compensation pack- of prospective analysis to be irrelevant ages to ensure nondiscrimination. The because there were no women or minori- companies were aware that they had to ties at glass ceiling levels. Furthermore, monitor salary data; however, there was a minorities plateaued at a lower level than lack of oversight for other forms of reward women. Generally, the highest-placed wo- and compensation, which play a signifi- man was at a higher reporting level to the cant role at the highest corporate levels. CEO than the highest-placed minority. Finially, the pilot reviews revealed that The few women and minorities found at although a company that contracts with the highest levels tended to be in staff the government assumes an obligation to positions, such as human resources, re- monitor its employment activities to en- search, or administration, rather than line sure all employees and applicants are positions, such as sales and production. treated in a nondiscriminatory manner, Since line positions directly affect a com- many of the companies in the study did pany's bottom line, these positions are not have adequate EEO/affirmative ac- generally considered the path to the exec- utive suite. This perception has been vali- tion records concerning recruitment, em- dated by a new study funded by the ployment, and developmental activities Women's Bureau of the Department of for management-type positions. Such Labor entitled "Breaking the Glass Ceil- records are essential for adequate moni- ing in the 1990s," This study analyzed toring of a company's fulfillment of its the internal career paths of female execu- affirmative action responsibilities. tives. The results of the research indicated that most of the women executives who None of the nine companies in the pilot broke through the glass ceiling were in study was cited for discrimination. This line rather than staff positions. does not mean that no violations were detected. Six of the companies entered The pilot reviews also revealed that or- into Conciliation Agreements for violation ganizations did not perceive equal oppor- of recordkeeping requirements involving tunity and access principles as a broad- applicant flow, refererals, and place- based corporate responsibility to be inte- ments. Two companies signed Letters of grated throughout every level and area of Commitment, also with regard to monitor- the organization, but rather as the respon- ing their recordkeeping and placement sibility of one individual or division. Fur- procedures. One company received a Let- thermore, there was generally no ter of Compliance after addressing a prob- centralized means to monitor or track de- lem in its pipeline leading to the executive velopmental opportunities and credential suite. In addition, follow up to the original building experiences, such as training pro- pilot study is now going on, since we are grams, developmental job rotations, and not only interested in what the companies committee assignments, to ensure that all accomplished in response to their regula- qualified employees were given considera- tory requirements, but more importantly, tion. For example, one company had a what has been achieved through requirement that in order to become voluntary efforts since the reviews were CEO, a candidate would need to have conducted, 424 July, 1992 Labor Law Journal Currently, a new round of corporate Glass Ceiling Commission, which is to be management reviews are also in progress, chaired by the Secretary of Labor. although none has yet been completed. At The Commission, composed of 21 mem- least twelve reviews are planned for this bers appointed by the President and con- fiscal year. Nine companies have already gressional leaders, is charged with been identified and scheduled. The nine conducting a study of opportunities for, current corporations cover such diverse and artificial barriers to, the advance- industries as the chemical, food, educa- ment of women and minorities to manage- tion, fiber glass, energy, insurance, utili- ment positions in business. The Solicitor ties, electronics and aerospace. The of Labor will serve as Counsel to the Com- companies range in size from approxi- mission, whose findings are to be reported mately $1 billion in sales to over $20 to both the President and Congress in billion. The corporations have been in ex- early 1993. istence from 24 to 100 years and employ an average of 13,000 people. Some Legal Issues Raised by the I cannot underscore how important di- Glass Ceiling Project rect CEO involvement has been in the We recognize that by their very nature, success of this initiative. What the pilot corporate management reviews delve into study showed was not some form of overt the heart of the corporate decision-making discrimination, but an attitude that led to process. Thus, employers are understanda- minorities and women being overlooked bly concerned about the confidentiality of for certain positions. When CEOs them- sensitive personnel data, such as succes- selves became aware of this problem they sion plans and total compensation pack- responded. Indeed, we found one CEO ages that might become available to who, on his own initiative, voluntarily es- competitors or others under the Freedom tablished an EEO overview committee to of- Information Act. Because of its sensi- "provide ongoing review of the corporate tivity to these concerns, OFCCP requests EEO program and efforts, as well as to only data relevant to the issues being re- develop future plans and encourage their viewed, and, where possible, examines enthusiastic acceptance." Another firm such data onsite. This was, in fact, the initiated a number of innovative pro- case with the nine companies in the pilot grams, such as setting up scholarship program. DOL regulations, consistent funds and internship programs for minor- with applicable exemptions under FOIA, ity and female students in communities provide that notice shall be provided to where its plants are located. the submitter regarding a FOIA request if disclosure could reasonably be expected to Thus, while corporations cannot man- cause substantial competitive harm, and age attitudes, they can manage behavior that the submitter shall have a reasonable with accountability, rewards, and punish- period to make an objection to the disclo- ment. As in all other important areas of sure."* concern, what gets measured in business gets done, what is not measured is ig- Both the Trade Secrets Act and the nored. The Glass Ceiling Initiative has trade secrets and personnel files exemp- brought the issue to the forefront and has tions under the Freedom of Information demonstrated to business the importance Act limit the release of confidential com- of shattering the barrier, so that it can no mercial and financial information, as well longer be ignored. And to assure that the as any personal information deemed to be issue remains on the front burner, the an invasion of privacy. Even so, these Civil Rights Act of 1991 established the provisions are not likely to protect the

••See CNA v. Donovan, 830 F2d 1132 (CA-DC 1987); cert, den., 108 US SCt 1270(1987). Glass Ceiling Initiative 425 identity of a company that has been the fied women, supported an inference of dis- subject of a compliance review once the crimination. The court observed that such investigation has been closed. I reluc- "evidence leads to a conclusion that a tantly say this because I recognize that glass ceiling of gender discrimination pre- the Glass Ceiling Initiative was initially vented Daines from making the step up trumpeted as absolutely and totally confi- with the City to an officials and adminis- dential. Legally, this position may not be trators position." ^ sustainable. The question of the various documents is less clear. While the Depart- While statistical tools may be invalua- ble in making out or supporting a case of ment is seeking to be sensitive to confi- discrimination, I want to emphasize that dentiality concerns, certainly Chrysler the Glass Ceiling Initiative is not a num- Corp. V. EEOC^ stands for the proposi- bers game, and it is definitely not about tion that affirmative action plans are dis- quotas or preferential treatment. When coverable and can be used against the you come right down to it, numbers are drafter. This being so, the FOIA exemp- legally less significant the higher up the tions become more problematic. corporate ladder you go. After all, we are Other questions likely to arise with re- talking about the upper reaches of the spect to the Glass Ceiling Initiative con- corporate structure, and there is only one cern problems of proof. For example, how CEO. Thus, the normal use of statistical will OFCCP and the Office of the Solicitor information that informs the standard make out a case under the Executive Or- compliance review becomes methodologi- der? OFCCP policy is to apply Title VII cally problematic. Can you put so much principles when interpreting parallel pro- freight on "disparate impact" when you visions under the Executive Order. There- are dealing with such small numbers com- fore, glass ceiling discrimination cases paring availability to incumbency? could be brought under either a disparate Having reviewed the work of DOL to treatment or disparate impact theory or date, I see the problem from a different both. perspective. It is extremely important In a 1990 federal court decision from that the Department not fall into the trap Minnesota, Dairies v. City of Mankato, of handing out "good conduct" badges for the plaintiff was a female city planner isolated results. Our concern is for process. who had applied for and been denied the And by process I mean to ensure that that position of Housing Director for the City. the systems of promotion and recruitment She brought suit under Title VII and the for top positions allow minorities and wo- applicable Minnesota nondiscrimination men to gain the credentials to put them- statute, using both disparate treatment selves into play for the top spots when and disparate impact theories. The court they become available, and to be selected found that the plaintiff had successfully or rejected on their merits. made out a claim of disparate treatment on the basis of sex and did not therefore Selection Criteria at the Highest go on to consider the plaintiff's claim of Levels disparate impact. In addition to the other Selection criteria at the highest levels of evidence supporting the plaintiff's claim management are often subjective, at least of disparate treatment, the court found in part. A company may select people for that the statistical evidence, particularly certain managerial positions because of the fact that no women had been ap- their "leadership qualities," however, that pointed officials and administrators with is defined and determined. While courts the City despite the availability of quali- have generally accepted the use of subjec-

5 441 us set 281 (1979). "• 754 F. Supp. 681 (D. Minn. 1980). 426 July, 1992 Labor Law Journal tive criteria in the context of professional custody. As one of my associates re- and managerial positions, they have marked, OFCCP's mission is to protect found liability where the subjective crite- human beings, not partners, ria were not used fairly or with adequate A related issue involves the common procedural safeguards. and extensive use of executive search In Adair v. Beech Aircraft Corp., the firms to recruit and screen applicants. court found that the plaintiff, a long-time One provision of OFCCP Compliance female employee who had applied for and Manual deals specifically with the use of been denied a promotion to a supervisory search firms. The provision makes clear position, had indeed been discriminated that it is a contractor's responsibility to against on the basis of sex and ordered her notify a search firm that the search firm, promoted to the supervisory position and in seeking candidates on its behalf, should awarded back pay. The judge expressly actively seek to include qualified minori- criticized the employer's decision-making ties, women, individuals with disabilities, process as a "wholly subjective judgment and covered veterans among those re- call," which "put in place a classic prima cruited and referred for jobs. Such an obli- facie case of discriminatory conduct in the gation stems from the contractor's own workplace," ^ affirmative action obligations under the Executive Order and the two other laws to In Ezold V. Wolf, Block, Schorr, & Solis-which it is subject as a government con- Cohen, Nancy Ezold was the only woman tractor, the Vietnam Era Veterans' Read- associate vying for a partnership in the justment Assistance Act of 1973, and litigation department of her law firm. The Section 503 of the Rehabilitation Act of partners' written evaluations of her com- 1973, petitors were unsparing. One candidate's evaluation stated, "disappears without Under the equal employment opportu- notice," One partner, referring to another nity (EEO) clause in its contracts, the another associate, wrote "I don't know contractor retains responsibility for solici- how he has lasted this long," In contrast, tations for employees placed on its behalf her evaluations were almost all positive, by a search firm or any other referral yet she was passed over for partnership source. Furthermore, a contractor that while her male competitors were pro- uses a search firm is obligated to monitor moted. referrals received both by sex and minor- ity group status, as part of its required The federal court in Philadelphia re- internal auditing and reporting systems. cently ruled that she was a victim of Clearly, a company that gives discrimina- discrimination due to the improper appli- tory instructions to a search firm would cation of subjective criteria, OFCCP and be liable for a violation of the Executive the Solicitor's office will carefully scruti- Order, This principle has long been estab- nize the use of such criteria to determine lished in cases involving employment if they are being used intentionally to agencies, but a contractor will also not be exclude qualified women and minority meeting its affirmative action require- candidates from consideration for mana- ments if it persists in using a search firm gerial positions (i,e, disparate treatment), that continually refers, for example, only or when such criteria has that effect in white males to the contractor. practice (i,e, disparate impact). This in- cludes the process by which associates are There also may be instances in which selected for partnerships in law firms. OFCCP would seek to hold the search firm Once you become a partner, however, you itself liable for acts of discrimination, by are removed from OFCCP's protective referring the matter to the EEOC for in-

' - F, Supp- (DC Kan, January 28, 1992), Glass Ceiling Initiative 427 vestigation under Title VII, or, where a ing, Inc., decision from the Los Angeles proper basis exists, asserting Executive County Superior Court, the plaintiff Order jurisdiction (e.g., the search firm, is claimed she had not been promoted to the a subcontractor of the prime). manager of credit position because of her Traditionally, the remedy for employ- sex. The court agreed, affirming the jury's ment discrimination is to make the victim $20.3 million dollar damage award and of discrimination whole, through back ordering the plaintiff promoted to an ex- pay, job placement, and/or front pay, ecutive position. where appropriate. But jobs at the man- Although I have touched mainly on liti- agement level tend to be unique. This fact gation-related legal issues, I would like to affects the availability of remedies for emphasize that the Civil Rights Act of persons who have been illegally denied 1991 expressly encourages the use of alter- positions or opportunities because of race native means of dispute resolution, such or gender. "Bumping" an incumbent em- as settlement negotiations and concilia- ployee has been sanctioned by the courts tion to resolve disputes arising under the in limited instances where a careful bal- Act. In addition, the Administrative Dis- ancing of the equities indicated that ab- pute Resolution Act of 1991 requires that sent such "bumping," the plaintiff's relief every agency designate a dispute resolu- would be unjustly inadequate. tion officer and that it develop an agency In a recent decision by the United ADR plan. The Department has re- States District Court for the District of sponded to the challenge by developing an Columbia, Underwood v. District of Co- ADR pilot project in our Philadelphia re- lumbia Armory Board, the court ordered gion, which at this time is limited to the the plaintiff to be placed in the position of use of mediation. While it is premature to armory manager, which she had been dis- predict the extent to which ADR will be criminatorily denied to her. The court rea- used in OFCCP cases, OFCCP is one of soned that the position of armory the agencies participating in the pilot pro- manager was "one-of-a-kind," "involving ject. We hope that ADR will prove useful a unique, top-level job, one for which no in the OFCCP context. equivalent vacancy could be projected." ^ Conclusion Similarly, in a 1986 Eleventh Circuit decision, Walters v. City of Atlanta, the Voluntary efforts play an important court affirmed the district court's decision role in the glass ceiling endeavor. The ordering that the plaintiff be elevated to heart of the Glass Ceiling Initiative is the the position of Director of the Atlanta promotion of equal opportunity, not man- Cyclorama, thereby "bumping" the in- dated results. We encourage the promo- cumbent Director. The court noted that tion of good corporate conduct through an while "bumping" is an extraordinary rem- emphasis on cooperative, not just correc- edy to be used sparingly, not to "allow the tive, problem solving. We also believe in bumping of a direct beneficiary of re- recognizing and rewarding those compa- peated discrimination by the direct vic- nies that are independently removing tim of the same acts of discrimination their own glass ceilings. Indeed, one of the would penalize the plaintiff who won his most important benefits of the widespread suit but lost the race to fill the position he publicity surrounding the Glass Ceiling had been unlawfully denied." ' Initiative has been the increasing corpo- rate awareness of glass ceiling issues. Individuals may also may file glass ceil- ing suits in state courts. In the recent Since the release of the Report, many Martin v. Texaco Refining and Market- corporate executives have come forward

8 - F. Supp.- (DC DofC February 10, 1992). «803F2d 1135 (CA-11 1986). 428 July, 1992 Labor Law Journal to let the Department of Labor know Companies also need to recognize, espe- what they are doing to remove their barri- cially given the changing demographics of ers. For example, some CEOs are making the work force, that recruiting and devel- affirmative action a line item and holding oping well-trained women and minorities managers personally responsible during are essential if such companies are to re- the yearly appraisal process for affirma- main competitive into the next century. tive action in their divisions. This is an Businesses with their eyes on the future example of managing behavior to produce understand the necessity of building a positive restilts. skilled and diverse work force throughout Voluntary compliance is also key for every level of the company. These busi- other reasons. Each corporate culture is nesses also know that a glass ceiling does distinct, and every company has its own not just prevent qualified women and mi- approach to the development of a man- norities from reaching their full potential, agement team; therefore, businesses, not it can also stunt the company's growth. OFCCP, are best situated to determine the optimum means of ensuring that qual- If the glass ceiling is allowed to remain, ified women and minorities are being it effectively cuts the pool of potential given the opportunity to advance. Busi- corporate leaders by eliminating more nesses, not OFCCP, are best equipped to than one half of the work force. It de- change the attitudes of managers who prives business of new leaders, new would cut short a person's career because sources of creativity, and would-be pio- he or she does not fit the manager's mold. neers with entrepreneurial spirit. Person- And the ideal way to guarantee that this ally, I believe the ceiling will be change in attitude happens is with a com- shattered, and I am pleased to be assist- mitment from the CEO and other senior- ing Secretary Lynn Martin in wielding a level officers to make equal opportunity a hammer to that end, key corporate objective toward becoming a premier employer. [The End]

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