Nondiscrimination and Equal Opportunity Policy

I. Policy Statement

Kernelis Studio, LLC, a provider of workforce development and career services under the Workforce Innovation and Opportunity Act (WIOA, Public Law 113-128), is committed to operating all of its WIOA-funded programs, activities, and services in a fair, equitable, and inclusive manner, free of discrimination.

This policy applies to all participants, applicants for participation, employees, applicants for employment, subcontractors, and members of the public seeking access to program services.

As a recipient of federal WIOA Title I financial assistance administered in Puerto Rico and delegated to local workforce development boards, Kernelis Studio fully complies with WIOA Section 188 and 29 CFR Part 38.

II. Equal Opportunity Is the Law (Required Notice)

It is against the law for Kernelis Studio, as a recipient of federal financial assistance, to discriminate on the following bases: against any individual in the United States on the basis of race, color, religion, sex (including pregnancy, childbirth, and related medical conditions, sex stereotyping, transgender status, and gender identity), national origin (including limited English proficiency), age, disability, or political affiliation or belief; or, against any beneficiary of, applicant to, or participant in programs financially assisted under Title I of WIOA, on the basis of the individual's citizenship status or participation in any WIOA Title I financially assisted program or activity.

Kernelis Studio must not discriminate in any of the following areas: deciding who will be admitted, or have access, to any WIOA Title I financially assisted program or activity; providing opportunities in, or treating any person with regard to, such a program or activity; or making employment decisions in the administration of, or in connection with, such a program or activity.

Recipients of federal financial assistance must take reasonable steps to ensure that communications with individuals with disabilities are as effective as communications with others. This means that, upon request and at no cost to the individual, recipients are required to provide appropriate auxiliary aids and services, and to take reasonable steps to provide meaningful access to limited English proficient individuals, including free language assistance services.

III. Protected Classes

Kernelis Studio will not discriminate in any aspect of its activities, services, programs, or employment on the basis of:

• Race, color, or national origin (including limited English proficiency)
• Religion or creed
• Sex (including pregnancy, childbirth and related medical conditions, sex stereotyping, transgender status, gender identity, and sexual orientation)
• Age (of any age; the Age Discrimination Act of 1975 applies without an age threshold)
• Disability (physical or mental)
• Citizenship or immigration status, as protected under federal law
• Participation in any WIOA Title I financially assisted program or activity
• Political affiliation or political belief
• Any other category protected by applicable federal or Puerto Rico law

IV. Prohibited Activities

Discrimination is strictly prohibited in:

• Admission, enrollment, and selection of participants into the program
• Access to workshops, learning materials, and program equipment
• Assessments, advising, tutoring, and individual interventions
• Access to support services where offered (refreshments, participant materials, loaned devices)
• Mentor assignment, job placement assistance, and employer connections
• Employment, advancement, or hiring opportunities within Kernelis Studio
• Post-program follow-up services

V. Equal Opportunity Officer (EO Officer)

The EO Officer is responsible for: (1) ensuring compliance with this policy across all program activities; (2) receiving, investigating, and resolving discrimination complaints; (3) coordinating with the Local Workforce Development Board, Puerto Rico's WIOA administering agencies, and the U.S. Department of Labor as needed; and (4) maintaining records of all incidents and actions taken.

VI. Complaint Procedure

Step 1. Filing a Complaint

Any person who believes they have experienced discrimination in connection with any program activity has the right to file a complaint, either with Kernelis Studio or directly with the U.S. Department of Labor, Civil Rights Center (CRC). Complaints to Kernelis Studio may be filed:

• In writing: [email protected]
• In person: Boys and Girls Club of Isabela, during program sessions
• By postal mail: Kernelis Studio, Isabela, Puerto Rico 00662
• Through the website: kernelis.studio/equal-opportunity (complaint form)

Step 2. Filing Deadline

Complaints must be filed within 180 calendar days of the alleged discriminatory act, pursuant to 29 CFR 38.69.

Step 3. Acknowledgment, Investigation, and Notice of Final Action

Kernelis Studio will acknowledge receipt of the complaint within 5 business days and complete its investigation promptly. A written Notice of Final Action will be issued no later than 90 days from the date the complaint was filed, as required by 29 CFR Part 38. If the complainant does not receive a Notice of Final Action within 90 days, they may file a complaint with the CRC within 30 days of the date that notice was due.

Step 4. Available Remedies

• Reinstatement in the program or in the denied service
• Retroactive access to materials, devices, or support services
• Adjustment of assessments or evaluations, where applicable
• Additional training for the personnel involved
• Referral to the Local Board, Puerto Rico's WIOA administering agencies, or the DOL CRC for external review

Step 5. Right to File with the U.S. Department of Labor

A complainant may file directly with the CRC at any time, whether or not a complaint has been filed with Kernelis Studio, and may also file with the CRC if dissatisfied with Kernelis Studio's final action:

VII. Accessibility and Language Access

Kernelis Studio ensures that all individuals have equitable access to the program, regardless of ability or language proficiency:

• Bilingual services (Spanish and English); the program operates primarily in Spanish
• Program materials available in Spanish and English
• Reasonable accommodations available for persons with disabilities at no cost; requests are encouraged 5 days in advance but will be honored whenever feasible
• Appropriate auxiliary aids and services provided upon request, at no cost
• Physical access: the Boys and Girls Club of Isabela meets ADA accessibility requirements
• Accessible technology: loaned devices with accessibility features enabled

VIII. Public Notice and Dissemination

This policy will be:

• Posted prominently at kernelis.studio/equal-opportunity
• Distributed to all participants during program orientation
• Included in the program materials packet
• Available at the Boys and Girls Club of Isabela facilities during the program
• Presented to the applicable WIOA administering entities as part of the provider compliance file

IX. Monitoring and Review

Kernelis Studio will review and update this policy annually, or immediately upon changes to federal law or WIOA regulations. Records of complaints, investigations, and corrective actions will be maintained for a minimum of three (3) years, pursuant to 29 CFR 38.43.

X. Final Statement of Compliance

Kernelis Studio does not discriminate in any WIOA-funded program, activity, or service. For more information or questions about this policy, contact the Equal Opportunity Officer at [email protected] or visit this page.