Federal Communications Commission
Washington, D.C. 20554
OMB 3060-1033
September 2003
FCC 396-C
FOR FCC USE ONLY
Multi-Channel Video Program Distributor EEO Program Annual Report

Read INSTRUCTIONS Before Filling Out Form

FOR COMMISSION USE ONLY
FILE NO.

B396 - 20130930AHK
SECTION I IDENTIFYING INFORMATION
A. Name of  Operator:
ASTOUND BROADBAND, LLC
MSO Name:
ASTOUND BROADBAND
B. Employment Unit's Mailing Address
401 KIRKLAND PARKPLACE
SUITE 500
City
KIRKLAND
State
WA
Zip Code
98033-
E-Mail Address (if available) 
FCC Registration Number:
0013907928
Emp. Unit ID # 12002
Application Purpose
New Program Report
Amendment to Program Report
Supplemental Investigation Sheet (SIS) Attached
C. County and State in which unit's employment office is located
CONTRA COSTA, CA
D. Category of Respondent (check applicable box)

Fewer than six (6) full-time employees during the selected payroll period: Complete Sections I, II and V
Six (6) or more full-time employees during the selected payroll period: Complete ALL sections of the Form 396-C and the Supplemental Investigation Sheet, if attached

E. Pay Period Covered by this Report (inclusive dates) 9/1/13-9/15/13
F. Attachments: (See "Exhibit" buttons, below.)

SECTION II COMMUNITY INFORMATION

System Communities Comprising Local Employment Unit
Ident No.
Name of Community
Location (State)
Type

Review the list of communities served on the previous year's submission and attach as Exhibit A any additions or deletions, using the format noted above. NOTE: APPLICABLE ONLY TO CABLE OPERATORS AND NOT TO OTHER MVPD UNITS.

[Exhibit 1]



SECTION III EEO POLICY AND PROGRAM REQUIREMENTS

Check YES or NO to each of the following questions. If answer to any question below is NO, attach as Exhibit B an explanation.
[Exhibit 2]

1.
Have you complied with the outreach provisions of the FCC's MPVD Equal Employment Opportunity Rule, 47 C.F.R. Section 76.75(b), during the twelve month period prior to filing this form?
Yes No
2. Do you disseminate widely your EEO Program to job applicants, employees, and those with whom you regularly do business? Yes No
3. Do you contact organizations, media, educational institutions, and other potential sources of applicants for referrals whenever job vacancies are available in your organization? Yes No
4. Do you undertake to offer promotions to positions of greater responsibility in a nondiscriminatory manner? Yes No
5. To the extent possible, do you seek out entrepreneurs in a nondiscriminatory manner and encourage them to conduct business with all parts of your organization? Yes No
6. Do you analyze the results of your efforts to recruit, hire, promote, and use services in a nondiscriminatory manner and use these results to evaluate and improve your EEO program? Yes No
7. Do you define the responsibility of each level of management to ensure a positive application and vigorous enforcement of your policy of equal employment opportunity and maintain a procedure to review and control managerial and supervisory performance? Yes No
8. Do you conduct a continuing program to exclude every form of prejudice or discrimination based upon race, color, religion, national origin, age, or sex from your personnel policies and practices and working conditions? Yes No
9. Do you conduct a continuing review of job structure and employment practices and maintain positive recruitment training, job design, and other measures needed to ensure genuine equality of opportunity to participate fully in all organizational units,occupations, and levels of responsibility? Yes No

SECTION IV ADDITIONAL INFORMATION

You may provide as Exhibit C any additional information that you believe might be useful in evaluating your efforts to comply with the Commission's EEO provisions. There is no requirement to provide additional data or information.
[Exhibit 3]



SECTION V CERTIFICATION

This report must be certified as follows:
A.   By the individual owning the reporting system if individually owned;
B.   By a partner, if a partnership; or
C.   By an officer, if a corporation or association.

I certify that to the best of my knowledge, information and belief, all statements contained in this report are true and correct.

Signed
Title
PRESIDENT
Date
09/28/2013
Name of Respondent
STEVE FRIEDMAN
Telephone No. (include area code)
4258961882

WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).



FORM FCC 396-C - SUPPLEMENTAL INVESTIGATION SHEET

Part I Employee Job Descriptions

Give brief job descriptions for employees in the job categories specified below. The number specified in the box indicates the number of different job descriptions that are to be submitted for each category. Job descriptions should include the position title and a brief description of the major duties and responsibilities of the individual(s) in the position.

1.
Officials and Managers
 
[Exhibit 4]
2.
Professionals

 

[Exhibit 5]
3.
Technicians
 1
[Exhibit 6]
4. Sales Workers
 
[Exhibit 7]
5.
Office and Clerical
 
[Exhibit 8]
6.
Craft Workers (skilled)
 
[Exhibit 9]
7.
Operatives (semi-skilled)
 
[Exhibit 10]
8.
Laborers (unskilled)
 
[Exhibit 11]
9.
Service Workers
 
[Exhibit 12]

Part II Inquiries Concerning EEO Program and Practices

Submit responses to the inquiries indicated by a "check" Responses should be brief, but must provide sufficient information to describe the employment unit's activity and efforts in the area of inquiry.

1.
Describe the employment unit's efforts to comply with the outreach provisions of 47 C.F.R. Section 76.75(b).
[Exhibit 13]
2.
Describe the employment unit's efforts to disseminate widely its equal employment opportunity program to job applicants, employees, and those with whom it regularly does business.
[Exhibit 14]
3.
Name the organizations, media, educational institutions, and other recruitment sources used to attract applicants whenever job vacancies become available.
[Exhibit 15]
4.
Explain the employment unit's efforts to promote in a nondiscriminatory manner to positions of greater responsibility.
[Exhibit 16]
5.
Describe the employment unit's efforts to encourage entrepreneurs to conduct business in a nondiscriminatory manner with all parts of its operation and provide an analysis of the results of those efforts.
[Exhibit 17]
6.
Report the findings of the employment unit's analysis of its efforts to recruit, hire and promote in a nondiscriminatory manner and explain any difficulties encountered in implementing its EEO program.
[Exhibit 18]
7.
Describe the responsibility of each level of the employment unit's management with respect to application and enforcement of its EEO policy and explain the procedure for review and control of managerial and supervisory performance.
[Exhibit 19]
8.
Describe the manner in which the employment unit conducts its continuing review of job structure and employment practices.
[Exhibit 20]
9.
Other Inquiries:
[Exhibit 21]

Part III EEO Public File Report

Attach a copy of the EEO public file report from the previous year. Cable entities are required to place annually such information as is required by 47 C.F.R. Section 76.1702 in their public files.

[Exhibit 22]

EMP UNIT ID: 12002
MSO NAME: ASTOUND BROADBAND
 
OPR NAME: ASTOUND BROADBAND, LLC

Approved by OMB
3060-1033



Exhibits
Attachment 6
Description
Broadband Technician Job Description


Exhibit 16
Description:
EXPLAIN THE EMPLOYMENT UNITS EFFORTS TO PROMOTE IN A NONDISCRIMINATORY MANNE

WAVEDIVISION HOLDINGS DISTRIBUTES ALL JOB POSTINGS INTERNALLY AND EVALUATES INTERNAL EMPLOYEE APPLICANTS FOR JOBS FIRST FOR A SUCCESSFUL JOB SKILL MATCH TO ENCOURAGE PROMOTION. INTERNAL CANDIDATE EVALUATIONS ARE CONDUCTED USING THE SAME NON-DISCRIMINATORY GUIDELINES AS THE COMPANYS STANDARD EXTERNAL HIRING PRACTICES. EMPLOYEES ARE PROVIDED WITH TRAINING OPPORTUNITIES TO INCREASE SKILL SETS THROUGH A COMPANY SPONSORED EDUCATION REIMBURSEMENT PROGRAM AND COMPANY PAID NCTI AND SCTE COURSES.

IN ADDITION, THE COMPANY IS IN THE PROCESS OF IMPLEMENTING A SIGNIFICANTLY MORE DETAILED AND ROBUST CAREER PATH PLANNING PROCESS BEFORE THE END OF 2013 IN ALL DEPARTMENTS. THE NEW PROCESS CONSISTS OF ALL EMPLOYEES AND THEIR MANAGERS WORKING TOGETHER TO IDENTIFY, MONITOR AND PROVIDE REGULAR FEEDBACK ON KEY DEVELOPMENT PRIORITIES AND GOALS THAT LEAD TO INCREASED SKILL SETS WHICH IN TURN ENHANCES ELIGIBILITY FOR PROMOTION TO POSITIONS OF GREATER RESPONSIBILITY.


Attachment 16


Exhibit 19
Description:
DESCRIBE THE RESPONSIBILITY OF EACH LEVEL OF THE EMPLOYMENT UNITS MANAGEMENT

WAVE REQUIRES ITS HIRING MANAGERS TO FOLLOW ESTABLISHED COMPANY PROCEDURES AND TO OBSERVE EEOC AND FCC REQUIREMENTS TO AVOID DISCRIMINATION IN HIRING ON THE BASIS OF: RACE, COLOR, RELIGION, NATIONAL ORIGIN, GENDER, AGE, MARITAL STATUS, VETERAN STATUS, SEXUAL ORIENTATION, AND THE PRESENCE OF A NON-JOB RELATED HANDICAP OR DISABILITY, OR ANY OTHER LEGALLY PROTECTED STATUS. WAVES OPERATIONS VICE PRESIDENT, SENIOR VICE PRESIDENT, HUMAN RESOURCES, EXECUTIVE VICE PRESIDENT, OPERATIONS, AND WAVES PRESIDENT AND CHIEF OPERATING OFFICER ENFORCE THIS REQUIREMENT THROUGH REGULAR REVIEW OF THE HIRING PROCESS AND FINAL CANDIDATE(S) SELECTION.

JOB POSTINGS ARE FIRST REVIEWED AND APPROVED BY THE SENIOR VICE PRESIDENT, HUMAN RESOURCES, CHIEF OPERATING OFFICER, AND PRESIDENT. INTERVIEW CANDIDATES ARE SELECTED FOR INTERVIEWS BASED ON QUALIFICATIONS AND SKILL REQUIREMENTS IDENTIFIED IN THE JOB POSTING. IN ADDITION, WAVE SELECTS INTERVIEW CANDIDATES BASED ON PREVIOUS WORK HISTORY, INDUSTRY AND JOB-RELATED EXPERIENCE, NETWORK OR CO-WORKER RECOMMENDATIONS, AND JOB-RELATED ABILITIES. MOREOVER, HIRING MANAGERS ALSO ENSURE COMPLIANCE BY INTERVIEWING FINAL CANDIDATES AND REVIEWING THE ENTIRE APPLICANT FLOW LOG PRIOR TO SENDING IT TO THE SENIOR VICE PRESIDENT, HUMAN RESOURCES FOR FINAL APPROVAL. JOB OFFERS ARE REVIEWED BY THE SENIOR VICE PRESIDENT, HUMAN RESOURCES AND EXECUTIVE VICE PRESIDENT, OPERATIONS, IN ADVANCE OF PRESENTATION TO THE FINAL CANDIDATE FOR CONSISTENCY IN THE APPLICATION OF WAGE POLICY BASED ON ESTABLISHED WAGE RANGES, THE APPROPRIATE WAGE RATE BASED ON EXPERIENCE, AND PARITY OF THE RECOMMENDED WAGE TO THE EXISTING TEAM. REVIEW AND CONTROL OF MANAGEMENT AND SUPERVISORY PERFORMANCE IS FURTHER ACCOMPLISHED THROUGH REGULAR MANAGEMENT PERFORMANCE REVIEWS IN WHICH REGIONAL MANAGERS MEET WITH THEIR SUPERVISORS TO REVIEW AMONG OTHER THINGS COMPLIANCE WITH WAVES RECRUITING AND HIRING POLICIES.

IN ADDITION, REGIONAL HUMAN RESOURCES REPRESENTATIVES ROUTINELY MEET WITH HIRING MANAGERS TO ENSURE COMPLIANCE WITH WAVES EEO POLICY AND ADHERENCE TO WAVES RECRUITING AND HIRING PRACTICES.


Attachment 19


Exhibit 20
Description:
DESCRIBE THE MANNER IN WHICH THE EMPLOYMENT UNIT CONDUCTS ITS CONTINUING REVIIEW

WAVES SENIOR VICE PRESIDENT, HUMAN RESOURCES, AND EXECUTIVE VICE PRESIDENT, BUSINESS AND LEGAL AFFAIRS, REGULARLY MONITOR WAVES EMPLOYMENT PRACTICES TO ENSURE COMPLIANCE WITH FEDERAL AND STATE LAWS AND REGULATIONS AND COMPANY POLICY. WAVES EMPLOYEE HANDBOOK, WHICH DOCUMENTS THE COMPANYS EMPLOYMENT POLICIES, IS REVIEWED ON A REGULAR BASIS BY OUTSIDE EMPLOYMENT COUNSEL, ENSURING UP TO DATE INFORMATION ON EMPLOYMENT REGULATIONS. IN ADDITION, MANAGEMENT AT ALL LEVELS REVIEW WAVES JOB STRUCTURE TO ENSURE APPLICABILITY WITH CURRENT TRENDS IN THE INDUSTRY. AS SKILL SET REQUIREMENTS CHANGE OR PRODUCT LINES ARE ADDED, WAVE EVALUATES ITS JOB STRUCTURE TO ENSURE THAT EXISTING PRACTICES MEET THE NEEDS OF OUR CUSTOMERS AND EMPLOYEES. IF NECESSARY, WAVE UPDATES JOB DESCRIPTIONS TO INCLUDE THESE CHANGES IN JOB STRUCTURE. PROMOTIONS, RAISES, REVIEWS AND OTHER EMPLOYEE PERFORMANCE FEEDBACK ARE REVIEWED BY WAVES SENIOR VICE PRESIDENT, HUMAN RESOURCES, PRESIDENT, AND CHIEF OPERATING OFFICER TO ENSURE EMPLOYEES RECEIVE EQUAL AND CONSISTENT TREATMENT FROM THE COMPANY. PROGRESSIVE DISCIPLINE, PARTICULARLY IN THE FINAL STAGES AND WHERE COMPLIANCE IS NOT CLEAR, IS REVIEWED WITH OUTSIDE EMPLOYMENT COUNSEL TO CONFIRM COMPLIANCE WITH EMPLOYMENT POLICIES, LAWS, AND REGULATIONS.

IN ADDITION, EMPLOYMENT POLICIES ARE EVALUATED CONTINUALLY WITH THE REVIEW AND APPROVAL OF EVERY NEW HIRE AND ASSOCIATED CANDIDATE SEARCH (APPLICANT FLOW LOG) BY THE OPERATIONS VICE PRESIDENT, SENIOR VICE PRESIDENT, HUMAN RESOURCES, PRESIDENT, AND CHIEF OPERATING OFFICER. WAVE INCORPORATES RECOMMENDATIONS FROM OUTSIDE COUNSEL INTO ITS HIRING POLICIES ON A ROUTINE BASIS OR AS NEEDED.


Attachment 20


Attachment 22
Description
Concord EEO Public File