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 - 20130930BCM
SECTION I IDENTIFYING INFORMATION
A. Name of  Operator:
ORLANDO TELEPHONE COMPANY, INC.
MSO Name:
B. Employment Unit's Mailing Address
4558 SW 35TH STREET
SUITE 100
City
ORLANDO
State
FL
Zip Code
32811-
E-Mail Address (if available) 
FCC Registration Number:
0008410102
Emp. Unit ID # 12745
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
ORANGE, FL
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) 8/11/2013 - 8/24/2013
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
VICE PRESIDENT, FINANCE
Date
09/30/2013
Name of Respondent
ARTHUR HAAS
Telephone No. (include area code)
4079968900

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: 12745
MSO NAME:
 
OPR NAME: ORLANDO TELEPHONE COMPANY, INC.

Approved by OMB
3060-1033



Exhibits
Exhibit 1
Description:
COMMUNITY INFORMATION

THE FOLLOWING SYSTEM COMMUNITY COMPRISES THE LOCAL EMPLOYMENT UNIT:

IDENT NO: FL1384
NAME OF COMMUNITY: ORLANDO
LOCATION (STATE): FLORIDA
TYPE: 4

Attachment 1


Attachment 6
Description
Communications Technician Job Description


Exhibit 16
Description:
ORLANDO TELEPHONE COMPANY RESPONSE TO QUESTION 4

ORLANDO TELEPHONE COMPANYS CEO HAS DELIVERED INSTRUCTION TO THE MANAGEMENT STAFF TO PROMOTE FROM WITHIN WHENEVER POSSIBLE. JOB DESCRIPTIONS ARE DISTRIBUTED FOR POSITION OPENINGS VIA EMAIL TO STAFF. INTERESTED AND QUALIFIED STAFF MEMBERS ARE INSTRUCTED TO NOTIFY HUMAN RESOURCES DIRECTLY IF THEY ARE INTERESTED. INTERNAL CANDIDATES MEETING THE JOB REQUIREMENTS ARE THEN SCHEDULED FOR AN INTERVIEW.
THE COMPANY SENDS STAFF TO TRAINING CLASSES TO PREPARE THEM FOR FUTURE POSITIONS. FOR EXAMPLE, CUSTOMER SERVICE TEAM LEADERS ARE SENT TO PRE-SUPERVISORY TRAINING SO THAT THEY ARE READY FOR A PROMOTION TO SUPERVISOR WHEN THE TIME IS RIGHT.
ORLANDO TELEPHONE COMPANY IS PROUD OF ITS DIVERSE WORKFORCE AND THE PHILOSOPHY OF PROMOTING FROM WITHIN WILL ALLOW THE WORKFORCE TO GROW WITHIN THE ORGANIZATION. THROUGH THESE MEASURES, ORLANDO TELEPHONE COMPANY PROMOTES EMPLOYEES TO POSITIONS OF GREATER RESPONSIBILITY IN A NONDISCRIMINATORY MANNER.


Attachment 16


Exhibit 19
Description:
ORLANDO TELEPHONE COMPANY RESPONSE TO QUESTION 7

THE CEO AND HUMAN RESOURCES TAKE DIRECT RESPONSIBILITY FOR ORLANDO TELEPHONE COMPANYS EEO POLICY.
THE CEO APPROVES EACH OPENING AND REVIEWS EACH JOB DESCRIPTION PRIOR TO POSTING. HE THEN TURNS THE RECRUITING PROCESS OVER TO THE DIRECTOR OF HUMAN RESOURCES. AT THE END OF THE PROCESS, THE DIRECTOR OF HUMAN RESOURCES DISCUSSES THE CANDIDATES WITH THE HIRING MANAGER AND THE CEO APPROVES THE DECISION BY SIGNING ALL OFFER LETTERS.
THE DIRECTOR OF HUMAN RESOURCES IS INVOLVED IN NEARLY EVERY INTERVIEW AND IN EVERY PERSONNEL DECISION. THE DEPARTMENT VICE PRESIDENT IS ALSO INVOLVED IN FINAL INTERVIEWS. DURING DISCUSSIONS REGARDING ALL HIRING DECISIONS, QUALIFICATIONS ARE DISCUSSED IN DETAIL AND APPLIED ACROSS THE BOARD TO EVERY APPLICANT. DURING THESE DISCUSSIONS, MANAGERS ARE REMINDED OF THEIR RESPONSIBILITIES UNDER THE COMPANY'S EEO POLICY, BOTH FOR HIRING DECISIONS AND IN THEIR DAY TO DAY MANAGEMENT OF STAFF. THIS PROCESS DOES NOT ALLOW FOR DISCRIMINATION AS THE MOST QUALIFIED CANDIDATE IS HIRED.
THE DIRECTOR OF HUMAN RESOURCES ATTENDS ANNUAL EMPLOYMENT LAW UPDATE SEMINARS TO KEEP CURRENT ON CHANGES IN ALL EMPLOYMENT LAWS, INCLUDING EEO LAWS. SHE THEN SHARES THIS INFORMATION WITH ALL MANAGEMENT STAFF DURING MANAGEMENT MEETINGS. DURING MANAGEMENT MEETINGS, THE DIRECTOR OF HUMAN RESOURCES REMINDS THE MANAGEMENT STAFF OF OUR EEO POLICIES AND THEIR RESPONSIBILITIES TO FOLLOW AND ENFORCE THOSE POLICIES.
THE COMPANYS MANAGERS AND SUPERVISORS ARE RATED ON COMPLIANCE WITH ALL POLICIES, INCLUDING THE COMPANYS EEO POLICY, DURING THEIR ANNUAL PERFORMANCE APPRAISAL MEETING. THIS SERVES AS AN ADDITIONAL OPPORTUNITY TO NOT ONLY ADDRESS PRIOR PERFORMANCE BUT ALSO TO ENSURE THAT EACH MANAGER/SUPERVISOR IS CLEAR ON THE EXPECTATIONS.


Attachment 19


Exhibit 20
Description:
ORLANDO TELEPHONE COMPANY RESPONSE TO QUESTION 8

ORLANDO TELEPHONE COMPANY IS CONSTANTLY REVIEWING ITS JOB STRUCTURE AND EMPLOYMENT PRACTICES. BECAUSE OUR EMPLOYMENT UNIT IS RELATIVELY SMALL (85 EMPLOYEES), THE DIRECTOR OF HUMAN RESOURCES IS INVOLVED IN EACH PERSONNEL DECISION AND ACTION. THIS PROVIDES FOR INSTANT FEEDBACK TO MANAGERS AS WELL AS CONSTANT REMINDERS OF OUR EEO POLICY AND PERTINENT LAWS. EACH MANAGER UNDERSTANDS AND SUPPORTS THE IMPORTANCE OF DIVERSITY IN OUR WORKFORCE.
EACH EMPLOYMENT ACTION INCLUDING HIRING, PROMOTION, CORRECTIVE ACTION AND TERMINATION IS REVIEWED BY THE DIRECTOR OF HUMAN RESOURCES, DEPARTMENT VP AND MANAGER PRIOR TO TAKING ANY ACTION. THIS ENSURES THAT EACH DECISION IS MADE ON MERIT ALONE.
THE DIRECTOR OF HUMAN RESOURCES AND DEPARTMENTAL VP ARE ALSO IN ATTENDANCE AT EACH EMPLOYEE PERFORMANCE APPRAISAL MEETING AND USE THE MEETING AS A TIME FOR THE EMPLOYEE TO SHARE CONCERNS. THE COMPANY ALSO HAS AN OPEN DOOR POLICY WHICH IS CLEARLY STATED IN THE EMPLOYEE HANDBOOK. THE OPEN DOOR POLICY IS ENCOURAGED AND SUPPORTED BY THE MANAGEMENT STAFF.


Attachment 20


Attachment 22
Description
Orlando Telephone Company 2013 EEO Public Inspection File Report