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 - 20190930ADG
SECTION I IDENTIFYING INFORMATION
A. Name of  Operator:
WAVEDIVISION VI, 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:
0015637911
Emp. Unit ID # 12134
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
YOLO, 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) 8/15/19-8/31/19
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, HUMAN RESOURCES
Date
09/30/2019
Name of Respondent
TRACY BRUTCHER
Telephone No. (include area code)
5127381271

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
 
[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
 1
[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: 12134
MSO NAME: ASTOUND BROADBAND
 
OPR NAME: WAVEDIVISION VI, LLC

Approved by OMB
3060-1033



Exhibits
Exhibit 12
Description:
SERVICE WORKERS JOB DESCRIPTION

THIS EMPLOYMENT UNIT DOES NOT CURRENTLY EMPLOY ANY PERSONS THAT FALL WITHIN THE JOB CATEGORY OF SERVICE WORKERS.

Attachment 12


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

WAVE HAS A STRONG CULTURAL FOCUS AROUND PROMOTING EMPLOYEES WITHIN THE COMPANY THROUGH ITS INTERNAL PRACTICES AND TRAINING OPPORTUNITIES. OUR INTERNAL TRAINING PROGRAM PROVIDES ALL EMPLOYEES WITH THE OPPORTUNITY TO DEVELOP WITHIN THEIR CHOSEN CAREER TRACKS. OUR DEDICATED TRAINING DEPARTMENT UTILIZES VARIOUS MODALITIES OF DELIVERY TO ENSURE ALL EMPLOYEES, REGARDLESS OF LEARNING STYLE, CAN LEARN AND ADVANCE IN THEIR SKILLSET AND CAREER TRACK. THIS TRAINING TEAM IS A CENTRALIZED TEAM, WHICH PROVIDES TRAINING THAT LEVERAGES PROGRAMS DEVELOPED ACROSS OUR COMPANY. IN TURN, THIS STREAMLINED APPROACH PROVIDES AN EXCELLENT OPPORTUNITY FOR OUR EMPLOYEES, WITHIN EACH REPORTING UNIT, TO PROMOTE WITHIN THAT UNIT, ACROSS THE WAVE FOOTPRINT AND BEYOND TO THE REST OF OUR LARGER ORGANIZATION.

MANY OF OUR POSITIONS HAVE AN INTERNAL CAREER TRACK THAT CLEARLY OUTLINES THE STEPS AND EDUCATION REQUIREMENTS NEEDED TO PROGRESS WITHIN THE CHOSEN TRACK. THESE PROGRESSION PLANS HAVE BEEN DEVELOPED IN PARTNERSHIP WITH EXTERNAL EDUCATIONAL ORGANIZATIONS, SUCH AS SCTE/NCTI, TO PROVIDE INDUSTRY CERTIFICATION TO OUR EMPLOYEES, WHICH WILL FOLLOW THEM BEYOND THEIR TIME AT WAVE. IN ADDITION, THE COMPANY OFFERS TRAINING WITHIN EACH CATEGORY TO DEVELOP TALENT WITHIN. WE UTILIZE A TRAINING DELIVERY SYSTEM THAT ALLOWS ALL EMPLOYEES TO VIEW AND PARTICIPATE IN TRAINING THAT IS AVAILABLE WITHIN THE ORGANIZATION. WITH CERTAIN CAREER PATH POSITIONS, WE FOCUS SOLELY ON INTERNAL RECRUITING BEYOND THE ENTRY LEVEL INTO THAT CAREER PATH. THESE POSITIONS ARE POSTED INTERNALLY ON OUR JOB BOARD AND AVAILABLE FOR ALL EMPLOYEES TO ACCESS.

OUR ANNUAL PERFORMANCE APPRAISAL PROGRAM PROVIDES ONE ON ONE INTERACTION WITH TEAM LEADERSHIP, WHERE DEVELOPMENT OPPORTUNITIES, CAREER PATH OPTIONS AND OTHER TOPICS BENEFICIAL TO THE GROWTH OF THE EMPLOYEE TAKE PLACE. ONE OF THE TENANTS OF OUR MISSION STATEMENT IS TAKE CARE OF EACH OTHER. WE UPHOLD THIS EXPECTATION IN OUR ANNUAL, MONTHLY AND/OR WEEKLY 1:1 DISCUSSIONS WITH OUR TEAMS. PERSONAL DEVELOPMENT IS A GOAL WITHIN WAVE WHICH IS SUPPORTED BY OUR MANY PROMOTIONAL OPPORTUNITIES. TO SUPPORT OUR EMPLOYEES IN MAXIMIZING THEIR CAREERS, WE PROVIDE THEM WITH COMPANY-FUNDED OPPORTUNITIES FOR GROWTH AND ADVANCEMENT, INCLUDING TUITION REIMBURSEMENT FOR POST-HIGH SCHOOL EDUCATION. WE ALSO PAY TUITION FOR COMPLETING RELEVANT COURSES THROUGH NCTI AND SCTE AND INCLUDE WAGE INCREASES FOR SUCCESSFUL COMPLETION.

WAVES EQUAL OPPORTUNITY EMPLOYMENT POLICY IS POSTED ON OUR WEBSITE AND AVAILABLE TO ALL EMPLOYEES. MANAGERS ATTEND LEADERSHIP TRAINING WHICH FOCUSES ON LEADERSHIP EXPECTATIONS INCLUDING THE COMPANYS POLICY ON EQUAL EMPLOYMENT OPPORTUNITY. SUPERVISORS AND MANAGERS ARE RESPONSIBLE FOR IMPLEMENTING OUR EEO PRINCIPLES IN ALL ASPECTS OF THEIR WORK. CONSISTENT WITH THE FCCS EEO POLICIES AND OUR OWN EEO COMMITMENTS, WHEN VACANCIES ARISE, WE RECRUIT INTERNALLY AND EXTERNALLY TO ENSURE THAT INFORMATION ABOUT OUR EMPLOYMENT OPPORTUNITIES IS WIDELY DISSEMINATED AND AVAILABLE TO OUR EMPLOYEES.


Attachment 16


Exhibit 17
Description:
DESCRIBE THE EMPLOYMENT UNITS EFFORTS TO ENCOURAGE ENTREPRENEURS TO CONDUCT

WAVE IS COMMITTED TO CONDUCTING BUSINESS WITH ALL PARTIES IN A NON-DISCRIMINATORY MANNER. WAVE REQUIRES VENDORS AND CONTRACTORS TO CONDUCT BUSINESS WITH ALL PARTS OF ITS OPERATIONS IN A NON-DISCRIMINATORY MANNER. WAVES STANDARD CONTRACTOR RETENTION AGREEMENT REQUIRES ALL VENDORS TO COMPLY WITH WAVES VENDOR CODE OF CONDUCT PRIOR TO ENGAGING IN BUSINESS WITH WAVE. IN ADDITION, WAVE SOLICITS BIDS FROM AS MANY VENDORS AS POSSIBLE, INCLUDING ENTREPRENEURS, AND DECISIONS ARE NOT BASED ON ANY PREFERENTIAL TREATMENT, BUT RATHER ON THE SET OBJECTIVE CRITERIA WHICH WE EVALUATE FAIRLY.

THE PERTINENT TEXT FROM WAVES VENDOR CODE OF CONDUCT IS SET FORTH BELOW:

EQUAL OPPORTUNITY EMPLOYER. WAVE PROMOTES A COOPERATIVE AND PRODUCTIVE WORK ENVIRONMENT BY SUPPORTING THE CULTURAL AND ETHNIC DIVERSITY OF ITS WORKFORCE. WAVE IS COMMITTED TO PROVIDING EQUAL OPPORTUNITY TO ALL EMPLOYEES AND APPLICANTS FOR EMPLOYMENT. THIS COMMITMENT IS REFLECTED IN ALL ASPECTS OF OUR DAILY OPERATIONS. WAVE RECRUITS, HIRES, TRAINS, PAYS, PROMOTES, AND DISCIPLINES EMPLOYEES WITHOUT REGARD TO RACE, COLOR, SEX, SEXUAL ORIENTATION, RELIGION, NATIONAL ORIGIN, MARITAL STATUS, AGE, DISABILITY, OR VETERAN STATUS. EQUAL EMPLOYMENT OPPORTUNITY IS REQUIRED BY LOCAL, STATE, AND FEDERAL LAWS, AS WELL AS BY WAVE POLICY. WAVE EXPECTS ITS VENDORS TO SHARE ITS COMMITMENT TO EQUAL OPPORTUNITY. THE VENDORS COMMITMENT MAY INCLUDE IDENTIFYING, PROCURING, AND PAYING FOR ANY REASONABLE ACCOMMODATION THAT MAY BE REQUIRED FOR A DISABLED REPRESENTATIVE OF THE VENDOR TO PERFORM HIS OR HER ESSENTIAL JOB FUNCTIONS WHILE ON WAVE PROPERTY OR WORKING ON WAVE-RELATED BUSINESS.

WAVES VENDOR CODE OF CONDUCT DESCRIBES WAVES COMMITMENT TO A COOPERATIVE AND PRODUCTIVE WORK ENVIRONMENT BY SUPPORTING THE CULTURAL AND ETHNIC DIVERSITY OF ITS WORKFORCE AND WAVES EXPECTATION THAT THE VENDOR SHARE WAVES COMMITMENT TO CONDUCT BUSINESS IN A NON-DISCRIMINATORY MANNER. WAVES STANDARD CONTRACTOR AGREEMENT ALSO REQUIRES ALL VENDORS TO COMPLY WITH ALL APPLICABLE LAWS AND REGULATIONS, INCLUDING LAW AND REGULATIONS RELATED TO EEO. WAVE CONDUCTS ITS BUSINESS OPERATIONS IN A DE-CENTRALIZED FASHION, AFFORDING A CONSIDERABLE DEGREE OF AUTONOMY TO ITS LOCAL MANAGERS TO RETAIN CONTRACTORS AND DEAL WITH VENDORS. THIS AUTONOMY ALLOWS MANAGERS TO PROMOTE WAVES COMMITMENT TO EQUAL OPPORTUNITY AND DIVERSITY OF A LOCAL BASIS IN MAKING DECISIONS REGARDING THE RETENTION OF VENDORS AND CONTRACTORS. WAVE REQUIRES ITS MANAGERS TO ADHERE TO WAVES PRINCIPLES REGARDING THE RETENTION OF MINORITY BUSINESS ENTERPRISES AND WOMEN BUSINESS ENTERPRISES, COMPLIANCE WITH FCC RULES AND REGULATIONS AND TO BE FAMILIAR WITH FEDERAL, STATE AND LOCAL REGULATIONS REGARDING DISCRIMINATION. WAVES CORPORATE MANAGEMENT TEAM PERIODICALLY DISCUSSES WAVES PRINCIPLES OF NON-DISCRIMINATION WITH ITS LOCAL MANAGERS IN AN ON-GOING EFFORT TO PROMOTE CULTURAL AND ETHNIC DIVERSITY IN WAVES WORKPLACE AS WELL AS AMONG THE VENDORS AND CONTRACTORS WAVE RETAINS. WAVE SUPPORTS THE EFFORTS OF MINORITY-OWNED BUSINESSES, SMALL BUSINESS ENTERPRISES AND ENTREPRENEURS IN THE COMMUNITIES IT SERVES BY RETAINING SUCH FIRMS WHENEVER REASONABLY POSSIBLE.


Attachment 17


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

WAVE IS ALWAYS ASSESSING THE MANNER IN WHICH WE EVALUATE THE STANDARDS, LEVELS AND EXPECTATIONS OF OUR JOB STRUCTURE. IN 2019, OUR COMPANY COMMISSIONED A SALARY SURVEY TO ENSURE WE ARE PAYING COMPETITIVE RATES IN OUR MARKETS. THIS ALSO GAVE US THE OPPORTUNITY TO REEVALUATE OUR JOB GRADES, CAREER PATH STRUCTURES AND OUR PROGRESSION PLANS FOR MANY OF OUR POSITIONS.

WAVE IS ALSO PREPARING TO TRANSITION TO NEW BUSINESS OPERATIONS SOFTWARE IN 2020, WHICH PERMITS US TO REVIEW ALL OF OUR INTERNAL PEOPLE PROCESSES AND WORK FLOWS WHILE IDENTIFYING OPPORTUNITIES TO IMPROVE OUR EMPLOYMENT PRACTICES.   

AN OPERATIONAL EXAMPLE OF THIS CONTINUOUS REVIEW IS HIGHLIGHTED IN THE RECENT HIRING OF OUR DIRECTOR OF SAFETY AND TRAINING. THIS POSITION IS NOW A NATIONAL POSITION THAT ALLOWS WAVE TO FALL UNDER AN ENHANCED CURRICULUM, WHILE CONTINUING THE BEST PRACTICES ALREADY IN PLACE. THESE ORGANIZATIONAL CHANGES PROVIDE EXCELLENT OPPORTUNITIES TO REVIEW THE WAY WE DO BUSINESS WHILE ENSURING WE ARE WORKING EACH DAY UNDER THE HIGHEST OF STANDARDS WITHIN THE WORKPLACE.

ALSO, IN 2019 WE HAVE INVESTED IN EXPANDING OUR HUMAN RESOURCES AND RECRUITING STAFF TO ENSURE WE ARE SUPPORTING THE CONTINUOUS IMPROVEMENT OF OUR POLICIES, PRACTICES, AND GUIDELINES. WE HAVE FOCUSED ON RE-EVALUATING EMPLOYMENT PRACTICES AND JOB STRUCTURES AS WE REALIGN THE COMPANY INITIATIVES AND DEPARTMENT STRUCTURES WHILE CONTINUING TO INCREASE OUR OPPORTUNITIES TO DIVERSIFY OUR WORKFORCE.


Attachment 20


Attachment 22
Description
Astound West Sacramento Public Inspection File 2018-2019