Cities Index.
Agenda packet

Santa Ana City Council
June 16, 2026

Document
Agenda packet
Meeting
June 16, 2026
Body
Santa Ana City Council
Pages
18
Original file
56.4 MB
Text extracted from the city's file for reading and search. Open the original on santa-ana.primegov.com. That file is the official record.

EXHIBIT 1

City Council
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6/16/2026

STATE

COMPENSATION

INSURANCE
FUND

HOME OFFICE

SAN FRANCISCO

ENDORSEMENT AGREEMENT

WAIVER OF SUBROGATION

BLANKET BASIS
EFFECTIVE JUNE 5, 2025 AT 12.01 A.M.

ALL EFFECTIVE DATES ARE
AT 12:01 AM PACIFIC

STANDARD TIME OR THE

TIME INDICATED AT

PACIFIC STANDARD TIME
AND EXPIRING JUNE 5, 2026 AT 12.01 A.M.

ORANGE COUNTY CHILDREN'S THERAPEUT
2215 N BROADWAY FL 1
SANTA ANA, CA 92706

WE HAVE THE RIGHT TO RECOVER OUR PAYMENTS FROM ANYONE
LIABLE FOR AN INJURY COVERED BY THIS POLICY. WE WILL

NOT ENFORCE OUR RIGHT AGAINST THE PERSON OR
ORGANIZATION NAMED IN THE SCHEDULE.

THIS AGREEMENT APPLIES ONLY TO THE EXTENT THAT YOU

PERFORM WORK UNDER A WRITTEN CONTRACT THAT REQUIRES YOU TO OBTAIN THIS AGREEMENT FROM US.

THE ADDITIONAL PREMIUM FOR THIS ENDORSEMENT SHALL BE

2.00% OF THE TOTAL POLICY PREMIUM.

SCHEDULE

PERSON OR ORGANIZATION

ANY PERSON OR ORGANIZATION

FOR WHOM THE NAMED INSURED

HAS AGREED BY WRITTEN

CONTRACT TO FURNISH THIS
WAIVER

JOB DESCRIPTION

BLANKET WAIVER OF

SUBROGATION
REP Dl
9255171-25

RENEWAL
SP
0-27-07-45
PAGE 1 OF

NOTHING IN THIS ENDORSEMENT SHALL BE HELD TO VARY, ALTER, WAIVE OR EXTEND

ANY OF THE TERMS, CONDITIONS, AGREEMENTS, OR LIMITATIONS OF THIS POLICY OTHER THAN AS ABOVE STATED. NOTHING ELSEWHERE IN THIS POLICY SHALL BE

HELD TO VARY, ALTER, WAIVE OR LIMIT THE TERMS, CONDITIONS, AGREEMENTS OR LIMITATIONS IN THIS ENDORSEMENT.

COUNTERSIGNED AND ISSUED AT SAN FRANCISCO:
2572 �!.�
JUNE 6, 2025
Ii��,� .di-£<��

PRESIDENT AND CEO
1 SC IF FORM 10217 (REV .4-2018) OLO DP 217
EXHIBIT 1

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AGREEMENT UNDER THE WORKFORCE INNOVATION AND OPPORTUNITY ACT THIS SUBAWARD AGREEMENT, made and entered into this _1st day of July, 2026, by and between the City of Santa Ana, a charter city and municipal corporation duly organized and existing under the Constitution and laws of the State of California ("CITY and Working Wardrobes for a New Start , a non -profit corporation identified by the ir assigned Unique Entity Identifier (UEI) Number 0004400718 ("SUBRECIPIENT").

RECITALS:

A. CITY has been designated a Local Workforce Development Area (LWDA) under the Workforce Innovation and Opportunity Act of 2014, Public Law 1-113-128 ("the Act") , Catalog of Federal Domestic Assistance (CFDA) Number 17.259 and Federal Award Iden tification Number (FAIN) AA253421455A6.

B. The State of California has created the LWDA to administer the Act programs operated by the State of California pursuant to the Act.

C. As a L WDA, CITY is entitled to receive federal funds to establish programs to increase the employment, retention and earnings of Participants, and increase occupational skills attainment by Participants, and as a result, improve the quality of the workforce, reduce welfare dependency, and enhance the productivity and competitiveness of the nation (“said program”).

D. On April 1, 2025, the City issued a Request for Proposal No. 25 -019A (“RFP”) by which it sought youth serving organizations to become members of the Youth Service Provider Network, referred to as You th Service Providers (YSPN) to deliver a youth program for the City.

SUBRECIPIENT submitted a responsive proposal that was selected by the City. A copy of SUBRECIPIENT’s proposal is incorporated herein by reference as if set forth in full.

SUBRECIPIENT is experienced in operating workforce development programs for at -risk youth that provide preparation for secondary and post -secondary education, occupational training, and employment skills for entry into the labor market.

E. SUBRECIPIENT is willing to operate said program pursuant to the Act and California law.

WHEREFORE, for and in consideration of the respective and mutual covenants and promises hereinafter contained and made, and subject to all t he terms and conditions hereof, the parties hereto do hereby agree as follows:

I.

SUBRECIPIENT'S OBLIGATIONS
A. SUBRECIPIENT agrees to provide the following services pursuant to said program, as more specifically set forth in SUBRECIPIENT'S Program Narrative contained in "Exhibit A", as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) per 2 CFR §200.332(b)(1)(ix), and in the Performance Indicators contained in “Exhibit B”, per 2 CFR EXHIBIT 2

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§200.332(e) and 2 CFR §200.328, both attached hereto and by this reference i ncorporated herein.

SUBRECIPIENT'S failure to provide said services may be grounds for CITY to readjust the level of payment to SUBRECIPIENT otherwise provided for hereinafter.

B. SUBRECIPIENT agrees to provide benefits to individuals who participate in the activities and services funded by this Agreement (" Participants") in accordance with the standards and requirements set forth in the Act.

C. SUBRECIPIENT agrees to perform the services set forth herein in a professional, timely and diligent manner.

D. SUBRECIPIENT shall provide wages and benefits to Participants in accordance with the standards and requirements of the Act, including Section 181 of the Act.

E. SUBRECIPIENT shall adhere to the Labor Standards described in the Act, including Section 181 of the Act.

F. SUBRECIPIENT agrees to comply with the "Complaint Handling Procedures Under the WIOA”, attached hereto as "Exhibit C" and incorporated herein as though fully set forth in 20 CFR 658.411. SUBRECIPIENT shall advise Participants of their rights to file complaints under the Act and the procedures for resolution of any complaints. CITY's procedures for handling complaints alleging a violation of the Act, regulations, grants, or other agre ements under the Act shall be followed and any decision of CITY, the State or the federal government relating to the complaint shall be binding and followed by SUBRECIPIENT. SUBRECIPIENTS who are employers shall operate a grievance system that incorporates CITY's procedures for resolution of complaints relating to the terms and conditions of employment; these procedures shall be approved in writing by CITY.

G. As a condition of this award of financial assistance under the Act to SUBRECIPIENT from CITY, SUBRECIPIENT assures, with respect to operation of all programs or activities funded with funds provided pursuant to the Act, and all agreements or arrangements to carry out such programs or activities, that it will comply fully with the nondiscrimination and e qual opportunity provisions of the Act (Section 188) and compliance with Equal Employment Opportunity provisions in Executive Order (E.O.) 11246, as amended by E.O. 11375 and supplemented by the requirements of 41 CFR Part 60 ; the Nontraditional Employment for Women Act of 1991; Title VI of the Civil Rights Act of 1964, as amended; section 504 of the Rehabilitation Act of 1973, as amended; the Age Discrimination Act of 1975, as amended; the Americans with Disabilities Act of 1990; and with all applicable r equirements imposed by or pursuant to regulations implementing those laws, including, but not limited to, 29 CFR Parts 33 and 37. The United States, the State of California and CITY have the right to seek judicial enforcement of this assurance.

H. SUBRECIPIENT agrees that no Participant(s) shall commence training prior to the approval of funding pursuant to Section 123 of the Act.

I. SUBRECIPIENT agrees to the following accounting, monitoring, auditing, and review requirements:

1. SUBRECIPIENT agrees to maintain such records and submit such EXHIBIT 2

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reports, data and information, on the form and containing such information, at such times as CITY may request or require regarding the performance of SUBRECIPIENT'S services or activities, costs or other data, inclu ding but not limited to, Participants' attendance, payroll records and job duty statements.

2. SUBRECIPIENT agrees to forward to the Santa Ana W ORK Center Administrative Office, 801 W. Civic Center Dr ., Suite 200, Santa Ana, California 92701 completed Workforce Innovation and Opportunity Act Application form and supporting documents; a complete Workforce Innovation and Opportunity Act Enrollment; any subsequent updates; Workforce Innovation and Opportunity Act Youth Test Scores form; Workforce Innovation and Opportunity Act Exit form upon completion/termination of active enrollment of Participant; and the Workforce Innovation and Opportunity Act Follow-Up form within 15 days following 30, 60, 90, 180, 270, and 360 days of exit. SUBRECIPIENT agrees to enter information on the State of California’s CalJobs database system as instructed and requested by the Santa Ana WORK Center Administration.

3. CITY, the State of California and the United States government and/or their representatives shall have access for purposes of monitoring, auditing and examining of SUBRECIPIENT'S activities, performance , books, documents, papers, records of SUBRECIPIENT SUBRECIPIENTs, bookkeepers, accountants, employees and Participants related to this Agreement. Such agencies or re presentatives shall also schedule on -site monitoring at their discretion. Monitoring activities may also include, but are not limited to, questioning employees and Participants and entering any premises or onto any site in which any of the services or act ivities funded hereunder are conducted or in which any of the records of SUBRECIPIENT are kept (2 CFR §200.330). Nothing herein shall be construed to require access to any privileged or confidential information as set forth in federal or state law.

4. In the event SUBRECIPIENT does not make the above -referenced documents available within the City of Santa Ana, California, SUBRECIPIENT agrees to pay all necessary and reasonable expenses incurred by CITY in conducting any audit at the location where said records and books of account are maintained.

5. All accounting records and evidence pertaining to all costs of SUBRECIPIENT and all documents related to this Agreement shall be kept available at the location where SUBRECIPIENT conducted the program, as well as in the County of Orange, for the duration of this Agreement and thereafter for three (3) years after completion of an audit.

Records which relate to (a) complaints, claims, administrative proceedings or litigation arising out of the performance of this Agreement, or (b) costs and expenses of this Agreement to which CITY, the State of California or the United States Government take exception, shall be retained beyond the three (3) years until resolution of disposition of such appeals, litigation, cl aims, or exceptions.

J. Without prejudice to any other section of this Agreement, SUBRECIPIENT shall, where applicable, maintain the confidential nature of information provided to it concerning Participants in accordance with the requirements of federal and s tate law. Notwithstanding the foregoing, SUBRECIPIENT agrees to submit to CITY, the State of California and/or the United States Government or their representatives, all records requested for administrative purposes, including audits, examinations, monito ring and verification of records submitted by SUBRECIPIENT, costs EXHIBIT 2

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incurred and services rendered hereunder.

K. SUBRECIPIENT agrees to complete a monthly Invoice form showing in detail the amount of money already expended by SUBRECIPIENT hereunder, as this is a cash reimbursement contract. Accounting records must be supported by such source documentation as invoices, bills, statements, proof of payment , such as cancelled checks, payment confirmat ions, account statements , paid bills, payroll records, time and attendance records, and contract and subgrant award documents (2 CFR §200.101(b)(2)) . SUBRECIPIENT agrees to submit the above -stated documents to the W DB Administrative Office, 801 W. Civic Center Dr., Suite 200 , Santa Ana, California, 92701, by the ten th (10th) day of the month following the month in which SUBRECIPIENT'S services are performed.

Should SUBRECIPIENT fail to deliver said documents to CITY within thirty (30) days of said deadline, CITY shall provide SUBRECIPIENT with written notice of such deficiency. If said deficiency is not corrected within thirty (30) days of mailing such written notice, CITY shall have the option to deobligate SUBRECIPIENT’s funds and cancel this Agreement by giving SUBRECIPIENT ten (10) days written notice thereof. SUBRECIPIENT shall either return to the CITY excess revenues over costs or use such excess revenues as program income for additional training activities authorized under the Act.

L. SUBRECIPIENT agrees to expend all funds in accordance with all applicab le federal, state and local laws and regulations. SUBRECIPIENT also agrees to provide , at SUBRECIPIENT'S own expense, supplies and other costs of said PROGRAM.

M. SUBRECIPIENT shall arrange independently for an audit that includes WIOA funds received from CITY, in accordance with the Act, 2 CFR 200.500 et seq. SUBRECIPIENT shall submit one original of each required audit report to CITY within thirty (30) days after the date received by SUBRECIPIENT. Should SUBRECIPIENT fail to comply with these requirements, CITY may , at its option, withhold payment of funds, disallow funds, or suspend additional grant funds.

N. SUBRECIPIENT shall not expend funds pursuant to this Agreement to provide services to any Participant where costs of training are paid for by any other person or entity.

O. SUBRECIPIENT shall comply with the provisions of Uniform Guidance 2 CFR Part 200 of the U.S. Office of Management and Budget (OMB) and all other applicable federal statutes and executive orders and their implementing regulations, including regulations at 29 CFR Part 97.

P. SUBRECIPIENT shall comply with the requirements of federal regulations found at 29 CFR Part 93, which provide that no appropriated funds may be expended by the recipient of a federal cont ract, grant, loan or cooperative agreement to pay any person for influencing or attempting to influence an officer or employee of any agency, member of Congress or an officer or employee of a member of Congress in connection with awarding of any federal co ntract, the making of any federal grant or loan, entering into any cooperative agreement and the extension, renewal, amendment or modification of any federal contract, grant, loan or cooperative agree ment.

SUBRECIPIENT shall sign a C ertification Regarding Lobbying to that effect in a form as set forth in "Exhibit E," attached hereto and by this reference incorporated herein. SUBRECIPIENT shall submit said signed Certification to CITY prior to performing any of its obligations under this Agreement and prior to any obligation arising on the part of CITY to pay any sums to SUBRECIPIENT under the terms and conditions of this Agreement.

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Q. SUBRECIPIENT agrees to provide a drug-free work place and to execute a Drug Free Workplace Certification as set forth in "Exhibit F" attached hereto and incorporated herein by this reference.

R. SUBRECIPIENT, in accordance with the Child Support Compliance Act, recognizes and acknowledges the importance of child and family support obligations and shall fully comply with all state and federal laws relating to child and family support enforcement, including, but not limited to: disclosure of information and compliance with earnings assignment orders, as provided in Chapter 8 (commencing with Section 5200) of Part 5 of Division 9 of the state Family Code; and, to the best of its knowledge is fully complying with the earnings assignment orders of all employees and is providing the names of all new employees to the New Employee Registry maintained by the California Employment Development Department (EDD).

S. SUBRECIPIENT agrees to comply with all applicable provisions of the Act, and all applicable federal regulations, including , but not limited to , the Code of Federal Regulations, Subtitle A —Office of Management and Budget Guidance for Grants and Agreements, as well as all applicable state and local regulations.

T. SUBRECIPIENT agrees to remain in compliance with the Certification Regarding Debarment (“Exhibit G ”), as required by the regulations implementing Executive Or der 12549, Debarment and Suspension, (2 CFR Part 180).

U. SUBRECIPIENT agrees to provide priority of services for veterans and eligible spouses pursuant to 20 CFR Part 1010 , and the regulations implementing priority of service for veterans and eligible spouses in Department of Labor job training programs under the Jobs for Veterans Act published at 73 Fed.Reg. 78132 on December 19, 2008.

V. SUBRECIPIENT acknowledges that the official name for the statewide system of providing employment and training t hrough the WIOA partnerships and various other local programs is “America’s Job Center”. To achieve the goals of this grant, it is important that the public has a quick and easy method to identify that the projects or programs they are taking part in are part of the “America’s Job Center”. SUBRECIPIENT agrees to place the America’s Job Center logo, in accordance with the State of California guidelines for such use, on all public materials , such as statements, press releases, brochures, advertisements, rep orts and other documents describing projects or programs funded in whole or in part with WIOA funds. When the America’s Job Center logo is used, SUBRECIPIENT may accompany it with the following statement, “The (Program Name) is a proud partner of the America’s Job Center network”. SUBRECIPIENT shall not use the America’s Job Center logo in any manner that would imply that the State of California endorses a commercial product, service or activity.

II.

CITY'S OBLIGATIONS

A. On May 28, 2025 , the CITY was awarded a Department of Labor Workforce Innovation and Opportunity Act youth grant of $817,644.00 for fiscal year 2025-2026, with a two-year performance period which dictates that 100% of the funding allocation must be obligated before the contact window closes on June 30, 2027. CITY agrees to pay to SUBRECIPIENT when, if and to the extent federal funds are received under the provisions of the Act a sum no t to exceed $200,000.00 for EXHIBIT 2

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SUBRECIPIENT'S performance in accordance with the Budget attached hereto as " Exhibit D" and incorporated herein by reference, during the period of this Agreement for Program Year 2026-2027.

Said sum shall be paid after CITY rec eives invoices submitted by SUBRECIPIENT as provided hereinabove.

B. Pursuant to 2 CFR §200.332(b)(4), the Indirect Cost Rate for the SUBRECIPIENT’s award shall be an approved federally recognized indirect cost rate negotiated between the SUBRECIPIENT and the Federal government, or, if no such rate exists, either a rate negotiated between the CITY and the SUBRECIPIENT, or a de minimis indirect cost rate as defined in 2 CFR §200.414(f) Indirect (F&A) costs.

C. SUBRECIPIENT has the ability to adjust line item amounts in the budget with the approval of the Executive Director, so long as the total Budget amount does not increase.

D. CITY agrees to provide for on -site monitoring reviews of said program operation at least annually. In addition, monthly desktop reviews of pertinent information will be conducted.

E. CITY has the right to de -obligate the funds hereunder , and take such funding back from SUBRECIPIENT, due to any of the following reasons: (a) lack of performance by SUBRECIPIENT; (b) lack of fiscal accountability of SUBRECIPIENT; or (c) decrease in available funding.

III.

TERM OF AGREEMENT

A. This Agreement shall commence on July 1, 202 6, and all duties arising under this Agreement shall have been performed by June 30, 2027. The Term o f this Agreement may be extended by a writing executed by the City Manager and the City Attorney. SUBRECIPIENT acknowledges and agrees that it must provide follow -up services for one (1) year after the Term, whether funded or not.

B. SUBRECIPIENT agrees to comply with the closeout procedures detailed in 2 CFR §200.343, including the following:

1. SUBRECIPIENT must submit, no later than ninety ( 90) calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award;

2. Unless the CITY authorizes an extension, SUBRECIPIENT must liquidate all obligations incurred under the Federal award not later than ninety (90) calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award;

3. SUBRECIPIENT must promptly refund any balances of unobligated cash that the CITY paid in advance or paid and that is not authorized to be retained by SUBRECIPIENT for use in other projects (See OMB Circular A-129 and 2 CFR §200.345);

4. SUBRECIPIENT must account for any real and personal property EXHIBIT 2

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acquired with Federal funds or received from the Federal government in accordance with 2 CFR §§200.310-200.316 and 2 CFR 200.329; and,

5. The CITY should complete all closeout actions for the Federal award no later than one year after receipt and acceptance of all required final reports.

IV.

INDEPENDENT CONTRACTOR

Consultant shall, during the entire term of this Agreeme nt, be construed to be an independent contractor and not an employee of the City. This Agreement is not intended nor shall it be construed to create an employer-employee relationship, a joint venture relationship, or to allow the City to exercise discreti on or control over the professional manner in which Consultant performs the services which are the subject matter of this Agreement; however, the services to be provided by Consultant shall be provided in a manner consistent with all applicable standards a nd regulations governing such services. Consultant shall pay all salaries and wages, employer's social security taxes, unemployment insurance and similar taxes relating to employees and shall be responsible for all applicable withholding taxes.

V.

WORKER'S COMPENSATION AND EMPLOYER'S RIGHTS

A. SUBRECIPIENT shall use appropriate funds received from CITY to provide workers' compensation to all those hired by SUBRECIPIENT under this Agreement.

B. SUBRECIPIENT shall have the right to hire, dismiss, or promote its employees or contract personnel hired under this Agreement so long as its hiring or dismissal policy or standard does not violate Title VII of the Civil Rights Act of 1964, Fair Labor Standards Act of 1938, or any other applicable law, and SUBRECIPIENT maintains itself as an Equal Opportunity employer.

VI.

APPLICABLE GUIDELINES

A. The parties hereto agree that SUBRECIPIENT shall comply with all applicable federal and state laws and regulations, including, but not limited to the Performance Indicators (Exhibit B ) and general program requirements described in Sections 2 and 116 of the Act , and applicable regulations, and the U.S. Department of Labor guidelines and regulations, including amendments or revisions made during the terms of this Agreement. Said applicable laws are hereby incorporated by reference and made part of this Agreement as though fully set forth herein.

B. SUBRECIPIENT also assures and certifies that:

1. SUBRECIPIENT acknowledges and confirms that the U.S. Depa rtment of Labor has established six (6) performance indicators for youth: (a) Percent of Participants who are in education/training activities, or in unsubsidized employment during the 2 nd quarter after exit ; (b) Percent of Participants who are in educat ion/training, or in unsubsidized employment during the 4 th quarter after exit ; (c) the median earnings of Participants in unsubsidized employment during the 2 nd quarter after exit; (d) Percent of Participants who obtain recognized postsecondary credential or secondary diploma during participation or within 1 year after exit; (e) Percent of Participants who, EXHIBIT 2

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during the program, are in education or training that leads to a recognized postsecondary credential or employment and who are achieving measurable skil l gains; and , (f) effective in serving employers .

SUBRECIPIENT agrees to implement and shall meet any additional performance indicators that may be subsequently required by the Workforce Innovation and Opportunity Act or by any other Federal, State, and local law.

2. SUBRECIPIENT shall comply with Title VII of the Civil Rights Act of 1964 (P.L. 88-352) and in accordance with Title VII of the Act, requiring that no person shall, on the grounds of race, color, religion, sex, age, disability or national origin be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under this Agreement.

3. SUBRECIPIENT shall comply with any and all federal laws limiting the political activity of employees hired under this Agreement.

4. SUBRECIPIENT shall comply with the requirements that no program under the Act shall involve political activities.

5. RECORD INSPECTION. SUBRECIPIENT shall provide the U.S.

Department of Labor and the Controller General, by and through any authorized representative, as well as the WIB Administrative Office, access to and the right to examine all records, books, papers or documents relating to the accounting and use of funds under this Agreement for a three -year period from and after the effective date of this Agreement.

6. No person with responsibilities in the operation of any program under the Act shall discriminate with respect to any program Participant or any application for participation in such program because of race, religion, color, national origin, sex, political affiliation or beliefs.

7. SUBRECIPIENT shall maintain appropriate standards for health and safety in work and training situations.

8. SUBRECIPIENT shall comply with general provisions, assurances, and execute the Assurances and Certifications attached hereto as "Exhibit H" and incorporated herein.

9. EQUAL OPPORTUNITY. Any literature distributed by
SUBRECIPIENT for the purpose of apprising businesses, Participants, or the general public of its programs under this Agreement shall state that its programs are supported by the City of Santa Ana and the Santa Ana Workforce Investment Board, and shall state that the program is an “equal opportunity employer/program” and that “auxiliary aids and services are available upon request to individuals with disabilities.”

10. Based on the population eligible to be served, or likely to be directly affected by the WIOA program or activity, the services or information may need to be provided in a language other than English in order to allow such population to be effectively informed about or able to participate in the program or activity. Pursuant to 29 CFR 37.35, SUBRECIPIENT must take reasonable steps to provide services and information in appropriate languages after considering the scope of the program or activity, and the size and concentration of the population that needs services or information in a language other than English.

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11. SUBRECIPIENT certifies that all property, finished or unfinished documents, data, studies and reports prepar ed or purchased under this Agreement, will be disposed of in accordance with the direction of the CITY. In addition, any tools and/or equipment furnished to the SUBRECIPIENT by the CITY and/or purchased by the SUBRECIPIENT with funds pursuant to this Agreement, will be limited to use within the activities outlined in this agreement and will remain the property of the United States Government and/or CITY. Upon termination of this Agreement, SUBRECIPIENT will immediately return such tools and/or equipment t o the CITY or dispose of them in accordance with the direction of the CITY.

12. SUBRECIPIENT certifies that this Agreement does not provide for the advancement or aid to any religious sect, church or creed, or sectarian purpose , nor does it help to support or sustain any school, college, university, hospital or other institution controlled by any religious creed, church, or sectarian denomination, as specified by Article XVI, Section 5, of the Constitution of the State of California, regarding separation of church and state.

13. PATENT, COPYRIGHTS AND RIGHTS IN DATA. The
SUBRECIPIENT will disclose to the CITY any invention, written product, or computer program developed, or data assembled , as a result of performance of work under this Agreement , within seventy-four (74) days of invention, development or assembly. The CITY, State of California, and U.S. Department of Labor will have the right to patent any invention and copyright any written product or computer program or data generated by SUBRECIPIENT. Upon written request, SUBRECIPIENT will transfer all pertinent information, specifications and right, title and interest to the designated agency.

14. INVENTIONS, PATENTS AND COPYRIGHTS.

A. Reporting Procedure. If any project produces patentab le items, patent rights, processes, or inventions in the course of work under a U.S. Department of Labor (DOL) grant or agreement, the SUBRECIPIENT shall report the fact promptly and fully to the CITY. The CITY shall report the fact to the Grant Officer, at the DOL. Unless there is a prior agreement between the CITY and the DOL and its representative on these matters, the DOL shall determine whether to seek protection on the invention or discovery. The DOL and its representative shall determine how the rights in the invention or discovery, including rights under any patent issued thereon, will be allocated and administered in order to protect the public interest consistent with the "Governmental Patent Policy" (President's Memorandum for Heads of Executiv e Departments and Agencies, August 23, 1971, and Statement of Government Patent Policy as printed in 36 FR 16889).

B. Copyright Policy.

1. Unless otherwise provided in the terms of the grant or agreement, when copyright - able material is developed in the course of or under a DOL Grant or agreement, the author and the CITY which developed the work is free to copyright material or to permit others to do so. The SUBRECIPIENT and the Workforce Development Board (W DB) shall have a royalty -free, nonexclusive an d irrevocable license to reproduce, publish, use and to authorize others to use all copyrighted material.

2. The DOL reserves a royalty -free, nonexclusive, and irrevocable license to reproduce, publish or otherwise use, and to authorize others to use, for Federal Government purposes:

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(a) The copyright in any work developed under any grant, sub -grant, or contract under a grant or subgrant; (b) Any right of copyright to which a grantee, subgrantee or a SUBRECIPIENT purchases ownership with grant supp ort; and , (c) SUBRECIPIENT shall comply with the requirements of 29 CFR § 97.34.

C. Rights to Data. The DOL and the CITY shall have unlimited rights to any data first procured or delivered under this Agreement.

15. CLEAN AIR / CLEAN WATER ACT. If the grant hereunder exceeds $100,000, SUBRECIPIENT must comply with Section 306 of the Clean Air Act [(42 USC 7606 ]; Section 508 of the Clean Water Act (33 USC 1368); Executive Order 11738 and Environmental Protection Agency (“EPA”) regulations (40 CFR P art 35) as any may now exist or be hereafter amended. Under these laws and regulations, the SUBRECIPIENT assures that:

(a) No facility to be utilized in the performance of the proposed grant has been listed on the EPA List of Violating Facilities;

(b) It will n otify CITY prior to award of the receipt of any communication from the Director, Office of Federal Activities, U.S. EPA, indicating that a facility to be utilized for the grant is under consideration to be listed on the EPA List of Violating Facilities; and,

(c) It will notify the CITY and the EPA about any known violation of the above laws and regulations.

16. SUBRECIPIENT agrees to adhere to the following STANDARDS OF CONDUCT:

a. General Assurance. Every reasonable course of action will be taken by SUBRECIPIENT in order to maintain the integrity of this expenditure of public funds and to avoid favoritism. This Agreement will be administered in an impartial manner, free from errors to gain personal, financial , political gain. SUBRECIPIENT, its off icers and employees, in administering this Agreement, will avoid situations which give rise to a suggestion that any decision was influenced by prejudice, bias, special interest or desire for personal gain.

b. Employment of Former State or CITY Employees. SUBRECIPIENT will ensure that any of its employees who were formerly employed by the State of California or CITY, in a position that could have enabled such individuals to impact policy regarding or implementation of programs covered by this Agreement, will not be assigned to any part or phase of the activities conducted pursuant to this Agreement for a period of not less than two (2) years following the termination of such employment.

c. Conducting Business Involving Relatives. No relative by blood, adoption or marriage of any executive or employee of SUBRECIPIENT will receive favorable treatment when considered for enrollment in programs provided by, or employment with, SUBRECIPIENT.

d. Conducting Business Involving Close Personal Friends and Ass ociates. Executives and employees of SUBRECIPIENT will be particularly aware of the varying degrees of influence that can be exerted by personal friends and associates and, in administering this Agreement, will exercise due EXHIBIT 2

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diligence to avoid situations which give rise to an assertion that favorable treatment is being granted to friends and associates. When it is in the public interest for SUBRECIPIENT to conduct business with a friend or associate of an executive or employee of SUBRECIPIENT, an elected official in the area or a voting or non -voting member of the Workforce Investment Board (WIB), a permanent record of the transaction will be retained.

e. Avoidance of Conflict of Economic Interest . No executive or employee of SUBRECIPIENT elected official in the area, or voting or non-voting member of a WDB, will solicit or accept money or any other consideration from a third person, for the performance of an act reimbursed in whole or part by SUBRECIPIENT or CITY. Supplies, materials, equipment or ser vices purchased with Agreement funds will be used solely for purposes asserted or allowed under this Agreement. No voting member of the WDB will cast a vote on the provision of services or vote on any matter which would provide direct financial benefit to that member or any business or organization which the member directly represents.

f. Salary and Bonus Limitations . All Subrecipients of WIOA program funds are required to comply with federal requirements regarding the limitations on salary and bonus pa yments in accordance with Public Law 109-149, Section 503.

VII.

HOLD HARMLESS

A. SUBRECIPIENT shall indemnify and save harmless CITY, its officers, agents and employees, from and against any and all damages to property or injuries to or death of any pe rson or persons, including property and employees or agents of CITY, and shall defend, indemnify and save harmless CITY, its officers, agents and employees, from any and all claims, demands, suits, actions or proceedings of any kind or nature, including, b ut not by way of limitation, workers' compensation claims, resulting from or arising out of the negligent acts, errors or omission of SUBRECIPIENT, its employees or subcontractors.

B. SUBRECIPIENT shall indemnify and save harmless CITY, its officers, agen ts and employees, from and against any and all damages to property or injuries to or death of any person or persons, including property and employees or agents of CITY, and shall defend, indemnify and save harmless CITY, its officers, agents and employees, from and against any and all claims, demands, suits, actions or proceedings therefore, resulting from or arising out of the intentional or malicious acts of SUBRECIPIENT, its employees or subcontractors.

VIII.

INSURANCE

SUBRECIPIENT shall procure and maintain for the duration of the agreement, the following insurance coverages:

MINIMUM SCOPE AND LIMIT OF INSURANCE

SUBRECIPIENT shall maintain limits of insurance coverage in the following minimum amounts and shall be at least as broad as:

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1. Commercial General Liability (CGL) : Insurance Services Office Form CG 00 01 covering CGL on an “occurrence” basis, including products and completed operations, property damage, bodily injury and personal & advertising injury with limits no less than $1,000,000 per occurrence and $2,000,000 aggregate.

2. Sexual Abuse or Molestation Liability (SAML) : If the CGL policy referenced above is not endorsed to include affirmative coverage for sexual abuse or molestation, SUBRECIPIENT shall obtain and maintain a policy covering Sex ual Abuse and Molestation with a limit of no less than $1,000,000 per occurrence or claim.

3. Automobile Liability (AL) : Insurance Services Office Form CA 00 01 covering Code 1 (any auto), with combined single limits of $1,000,000. In the event SUBRECIPIENT does not maintain commercial automobile liability insurance, City will accept evidence of personal automobile insurance with existing limits, which can be lower than $1,000,000.

4. Workers’ Compensation (W/C) : as required by the State of California, with stat utory limits, and Employer’s Liability Insurance with limit of no less than $1,000,000 per accident, per employee, per policy for bodily injury or disease. This requirement can be waived if SUBRECIPIENT has no employees.

If SUBRECIPIENT maintains broader coverage and/or higher limits than the minimums shown above, City requires and shall be entitled to the broader coverage and/or the higher limits maintained by SUBRECIPIENT. Any available insurance proceeds in excess of the specified minimum limits of insurance and coverage shall be available to City.

Other Insurance Provisions
The insurance policies are to contain, or be endorsed to contain, the following provisions:

1. CGL, SAML and AL policies: City of Santa Ana, its City Council, its officers, officials , employees, agents, and volunteers are to be covered as additional insureds with respect to liability arising out of work or operations performed by or on behalf of the SUBECIPIENT including materials, parts, equipment, and personnel furnished in connecti on with such work or operations.

2. All required insurance policies: Insurance company(ies) agrees to waive all rights of subrogation against City, its City Council, its officers, officials, employees, agents, and volunteers for losses paid under the terms o f any policy which arise from work performed by SUBRECIPIENT for City.

3. All required insurance policies: For any claims related to this contract, SUBRECIPIENT’s insurance coverage shall be primary and any insurance maintained by City, its City Council, its officers, officials, employees, agents, or volunteers shall not contribute with it.

4. All required insurance policies: A severability of interest provision must apply for all the additional insureds, ensuring that SUBRECIPIENT’s insurance shall apply separat ely to each insured against whom a claim is made or suit is brought, except with respect to the insurer’s limits of liability.

5. Each insurance policy required herein shall provide that coverage shall not be canceled, suspended, voided, reduced in coverage o r in limits, non -renewed by the carrier, or materially changed except after thirty (30) days prior written notice has been given to City. Ten (10) days prior written shall be provided to City for policy cancellation or non -renewal due to non - payment.

6. Certificate Holder on each Evidence of Insurance certificate shall be: City of Santa Ana, Attention: Risk Management Division, 20 Civic Center Plaza , Santa Ana, CA 92701. The EXHIBIT 2

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name and location of event should be included in the Description of Operations secti on of each certificate.

Self-Insured Retentions
Self-insured retentions must be declared to and approved by the City. City may require SUBRECIPIENT to purchase coverage with a lower retention or provide proof of ability to pay losses and related investigations, claim administration, and defense expenses within the retention.

Acceptability of Insurers
Insurance is to be placed with insurers authorized to conduct business in the state of California with a current A.M. Best rating of no less than A:VII, unless otherwise acceptable to City.

Verification of Coverage
SUBRECIPIENT shall furnish City with original Certificates of Insurance including all required amendatory endorsements (or copies of the applicable policy language effecting coverage required by this clause) and a copy of the Declarations and Endorsement Page of the CGL policy listing all policy endorsements to City before work begins. However, failure to obtain the required documents prior to the work beginning shall not waive Permittee’s obligatio n to provide them. City reserves the right to require complete, certified copies of all required insurance policies, including endorsements required by these specifications, at any time.

Claims Made Policies
If any of the required policies provide coverage on a claims-made basis:

1. The retroactive date must be shown and must be before the date of the contract or the beginning of work.

2. Insurance must be maintained and evidence of insurance must be provided for at least three (3) years after completion of work.

3. If coverage is canceled or non -renewed, and not replaced with another claims-made policy form with a retroactive dat e prior to the contract effective date, Company must purchase “extended reporting” coverage for a minimum of three (3) years after completion of work.

Subcontractors
SUBRECIPIENT shall require and verify that all sub -contractors maintain insurance meeting all the requirements stated herein, and SUBRECIPIENT shall ensure that City is an additional insured on insurance required from sub-contractors.

Special Risks or Circumstances
City reserves the right to modify these requirements, including limits, based on the nature of the risk, prior experience, insurer, coverage, or other special circumstances.

IX.

CORPORATE STATUS

All corporate SUBRECIPIENTs shall be in good standing, without suspension by the California Secretary of State, Franchise Tax Board or Internal Revenue Service. Any change in corporate status or suspension shall be reported immediately to CITY.

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X.

ASSIGNABILITY

None of the duties of, or work to be performed by, SUBRECIPIENT under this Agreement shall be subcontracted or assigned to any agency, consultant, or person without the prior written consent of CITY. SUBRECIPIENT must submit al l subcontracts and other agreements that relate to this Agreement to CITY. SUBRECIPIENT acknowledges and agrees that it must follow procurement regulations for subrecipients (2 CFR §200.317). No subcontract or assignment shall terminate or alter the legal obligations of SUBRECIPIENT pursuant to this Agreement.

XI.

LAWS GOVERNING THIS AGREEMENT

In its performance under this Agreement, SUBRECIPIENT shall fully comply with the requirements of the following, whether or not otherwise referred to in this Agreement:

1. The Act and all applicable federal statutes, regulations, policies, procedures and directives, including but not limited to, 2 CFR Part 200 and 20 CFR Parts 651 and 654

2. All applicable State statutes, regulations, policies, procedures and directives;

3. All applicable CITY policies, procedures and directives;

4. All applicable local ordinances and requirements, including use permits and licensing;

5. Court orders applicable to its operation; and,

6. The terms and conditions of this Agreement.

If any of the foregoing is enacted, amended, or revised, SUBRECIPIENT will comply with such or will notify CITY after enactment or modification that it cannot so comply. CITY may thereupon terminate this Agreement, if necessary.

XII.

EXCLUSIVITY AND AMENDMENT OF AGREEMENT

This Agreement supersedes any and all other agreements, either oral or in writing, between the parties hereto with respect to the employment of SUBRECIPIENT by CITY, and contains all the covenants and agreements between the parties with respect to such employment. Each party to this Agreement acknowledges that no representations, inducements, promises or agreements, orally or otherwise, have been made by any party, or anyone acting on behalf of any party, which are not embodied herein, and that no other agreement or amendment hereto shall be effective unless executed in writing and signed by both CITY and SUBRECIPIENT.

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XIII.

FRAUD

SUBRECIPIENT shall immediately report to CITY all instances and facts concerning possible fraud, abuse or criminal activity relating to expenditure or receipt of funds under this Agreement.

XIV.

CONTINGENCY OF FUNDS

SUBRECIPIENT acknowledges that approval of and funding for this Agreement is contingent upon State approval, and funds received or obligated from the State of California to CITY.

If such approval of funds is not forthcoming, or is otherwise limited, CITY shall immediately notify SUBRECIPIENT. Within twenty (20) days of receipt of such notice, SUBRECIPIENT shall modify or cease operations as directed by CITY and negotiate necessary modification to this Agreement and/or reimbursement of costs incurred hereunder.

XV.

TERMINATION

A. This Agreement may be terminated by either party at its sole discretion, upon thirty (30) days written notice to the other party. Notice shall be deemed served on the date of mailing. However, SUBRECIPIENT may not terminate this Agreement if undue hardship will result to any Participant.

B. In the event SUBRECIPIENT defaults by failing to fulfill all or any of its obligations hereunder, CITY may declare a default and termination of this Agreement by written notice to SUBRECIPIENT, which default and termination shall be effective on a date stated in the notice which is to be not less than ten (10) days after certified mailing or personal service of such notice, unless such default is cured before the effective date of termination stated in such notice. If terminated for cause, CITY shall be relieved of further liability or responsibility under this Agreement, or as a result of the termination thereof, including the payment of money, except for payment for approved expenses incurred for services satisfactorily and timely performed prior to the mailing or service of the notice of termination, and except for reimbursement of (1) any payments made for services not subsequently performed in a timely and satisfactory manner, and (2) costs incurred by CITY in obtaining substitute performance.

XVI.

DISPUTES

Except as otherwise provided in this Agreement, any dispute concerning any question arising under this Agreement shall be decided by CITY. In such a case CITY shall reduce its decision to writing and mail or otherwise furnish a copy ther eof to SUBRECIPIENT. The decision of the City shall be final and conclusive unless within thirty (30) calendar days from the mailing or delivery of such copy, CITY receives from SUBRECIPIENT written request to appeal said decision.

Procedures governing t he appeal shall be prescribed by CITY and/or the State of California in accordance with the Act and all corresponding regulations and OMB circulars. Pending final disposition of the appeal, SUBRECIPIENT shall act in accordance with CITY's decision unless the dispute involves a change order.

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XVII.

BREACH - SANCTIONS

If, through any cause, SUBRECIPIENT violates any of the terms and conditions of this Agreement, and/or prior agreements whereby grant funds were received by SUBRECIPIENT pursuant to this Agree ment, or if SUBRECIPIENT reports inaccurately or if any Audit Report makes disallowances, SUBRECIPIENT shall promptly remedy its acts or omissions and/or repay CITY all amounts due CITY as a result of SUBRECIPIENT's violation. For any such failures or vio lations, CITY shall also have the right at its sole discretion to either: (1) discontinue program support until such time as SUBRECIPIENT fulfills its obligations or remedies all violations of this Agreement or prior agreements; and/or (2) collect outstan ding amounts as determined by CITY due CITY by offsetting or debiting from current claims or invoices, if after thirty (30) days' written notice SUBRECIPIENT has failed to repay same or a repayment schedule has not been made; and/or (3) terminate this Agre ement by giving written notice to SUBRECIPIENT of such termination in accordance the notice provision in Paragraph XVIII herein below.

XVIII.

NOTICES

All notices, reports and correspondence between the parties hereto respecting this Agreement shall be in writing and deposited in the United States Mail, postage prepaid, addressed as follows:

CITY: City of Santa Ana
Manager, WDB Administrative Office
P.O. Box 1988 (M-76)
Santa Ana, CA 92702

CLERK: City Clerk
City of Santa Ana
20 Civic Center Plaza (M-30)
P.O. Box 1988
Santa Ana, CA 92702-1988
Telefacsimile (714) 647-6956

SUBRECIPIENT: Working Wardrobes for a New Start
2000 E. McFadden Ave Ste 100 Santa Ana 92705
Phone: (714) 210-2460

XIX.

MERGER

This Agreement, together with the attachments hereto, expresses the total understanding of the parties. There are no oral understandings of the parties or terms and conditio ns other than as stated herein.

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XX.

VALIDITY

The invalidity in whole or in part of any provision of this Agreement shall not void or affect the validity of any other provision of this Agreement.

XXI.

MISCELLANEOUS PROVISIONS

a. Each undersigned represents and warrants that its signature hereinbelow has the power, authority and right to bind their r espective parties to each of the terms of this Agreement, and shall indemnify CITY fully, including reasonable costs and attorney’s fees, for any injuries or damages to CITY in the event that such authority or power is not, in fact, held by the signatory or is withdrawn.

b. All Exhibits referenced herein and attached hereto shall be incorporated as if fully set forth in the body of this Agreement.

{Signatures on following page}

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IN WITNESS WHEREOF, the parties hereto have executed this Agreement the da te and year first above-written.

ATTEST: "CITY"

_________________________ By: __________________________ Jennifer Hall Alvaro Nuñez
City Clerk City Manager

APPROVED AS TO FORM:

Sonia R. Carvalho “SUBRECIPIENT”
City Attorney

By: ____________________ By: ___________________________ Andrea N. Garcia Name: Bonni Pomush
Senior Assistant City Attorney Title: Chief Executive Officer Tax ID #: EIN 33-0669145

RECOMMENDED FOR APPROVAL:

_________________________
Michael L. Garcia
Executive Director
Community Development Agency

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EXHIBIT A
Workforce Innovation & Opportunity Act
Youth Program Provider
Working Wardrobes
2026-2027
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ANSWERS TO QUESTIONS

1. Experience/Qualifications
A. Working Wardrobes for a New Start (Working Wardrobes) is a nonprofit organization founded in 1990. For over 35 years, the organization has provided comprehensive workforce development services—including job training, life skills workshops, job placement assistance, and professional wardrobing—to more than 130,000 individuals. The mission of Working Wardrobes is to help people overcome barriers to gainful employment. The organization serves low-income individuals from marginalized communities who are seeking to enter or re-enter the workforce or advance their careers. Special attention is given to working-age youth, persons of color, veterans, seniors, justice-involved individuals, and those who have experienced homelessness, substance abuse, domestic violence, chronic illness, or long-term unemployment. In 2025, Working Wardrobes reached 10,238 individuals. The organization is a recognized leader in workforce development across Southern California, known for its quality, adaptability, and deep community engagement.

B. The Working Wardrobes corporate headquarters and Career Success Center are located at 2000 E. McFadden Ave., Santa Ana, CA 92705, near the intersection of McFadden Ave. and Williams St., with convenient access to the CA-55 and CA-5 freeways.

C-D. The Career Success Center facility operates Monday through Friday, from 8:00 AM to 5:00 PM. Its central location, easy access via public transportation, ample free parking, and client- centered service layout create a welcoming environment with a secured lobby, friendly front desk attendants, and relatable staff who foster trust and engagement.

E1-4. For 2026, Working Wardrobes had an operating budget of $4,885,00. The organization employs a team of 35 professionals with expertise in career navigation, job development, and client services. Key leadership includes Bonni Pomush, Chief Executive Officer; Derek Benson, Chief People & Operations Officer; and Bianca Herrera, Director of Client Services. The organization's funding sources include contract and MOU revenue, private grants from corporations and foundations, individual contributions, fundraising events, social enterprise revenue, and in-kind donations.

Working Wardrobes has collaborated with WIOA funded programs by referring clients for direct services. The organization is a subcontractor with the City of Santa Ana working with CA4ALL and SAY youth programs, as well as 12 youth-focused community partners to deliver workshops and wardrobing services through select service programming. This collaboration highlights the organization’s ability to provide impactful workforce development services and effectively engage with a diverse network of community partners.

In 2025, young adults (16-24) accounted for 49% of the overall population Working Wardrobes served, representing the largest service population, highlighting the organization’s prioritization and significant impact on the youth community.

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2. Proposed Program
A. The Rebuilding Careers Program for Young Adults, a 12-month program proposed by Working Wardrobes, is designed to provide full case management workforce development services to out-of-school youth, ages 16-24, in Santa Ana. Over the 12-month program period, the program will achieve the following objectives:
● Provide Career Coaching, Mentorship, and Exploration
Pair each participant with the program’s dedicated 1.0 FTE Career Navigator (Case Manager) who will provide personalized guidance, career assessments and goal setting.

Leverage the expertise of volunteer Career Coaches with HR related experiences to provide one-on-one resume and interview preparation.
● Increase Workforce Readiness
Provide workforce readiness training to 20 out-of-school youth, through a workshop series that includes resume building, job search strategies, interview preparation, financial literacy, and workplace success techniques, equipping participants with the essential skills to confidently navigate the job market. Focus on developing key soft skills, including time management, problem-solving, teamwork, and communication, while supporting participants in cultivating vital personal and professional attributes such as responsibility and work ethic—critical for long-term career growth and advancement. Offer both in-person and self-paced learning options to accommodate diverse learning styles and ensure that all clients have the flexibility to engage with the material in a way that best supports their needs.
● Provide Paid Work Experience (WEX)
Provide up to 10 clients with approximately 120 hours of paid work experience at host sites in high-demand industries or at Working Wardrobes locations. Each host site will be vetted to ensure they provide a safe learning environment that focuses on the development of both soft skills and technical job-related skills. This includes on-the-job training and exposure to career pathways in high demand industries like healthcare, transportation, manufacturing, retail, logistics, customer service, and more. Paid work experience opportunities will be provided in partnership with regional employers like hospitals, hospitality groups, IT service providers, and through in-house placements at Working Wardrobes’ social enterprises, such as The Hanger Outlets, Donation Center and Career Success Center. The (.2 FTE) Retail Store Manager at the Hanger Outlet Store will serve as the WEX Supervisor participating in the recruitment and onboard of all participants. They will also oversee scheduling, approve timesheets and work closely with the Career Navigator to share performance progress. ● Skill-Based Certification/Training Enrollment and Tuition Support Connect participants to a WIOA-approved education or training program, that will lead to attainment of a postsecondary credential or a secondary school diploma during participation in or within one year after exit from the program. These programs will be in fields of interest to the participants with an emphasis on high-demand industries EXHIBIT 2

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(such as construction, manufacturing, IT, culinary arts, and transportation). We will leverage community partners and education programs that offer free to low-cost programs, when possible, such as Santa Ana Community College Continuing Education.

An average of $800 per participant of financial assistance will help support tuition fees, required supplies such as uniforms, tools and equipment. The Career Navigator will assist the client in reviewing, selecting and enrolling in the certification program by accompanying tours of the facility and attending enrollment sessions. If a GED is required for enrollment but not yet earned, the Career Navigator will help participants enroll in alternative education programs to obtain it prior to enrollment in a postsecondary education program.
● Offer Wraparound Supportive Services and Resources
Address barriers such as transportation, food insecurities, and financial instability by providing resources like gasoline debit cards, bus passes, identification assistance, background checks, grooming products, and Working Wardrobes’ signature professional wardrobing services with the support of volunteer Personal Stylists located at its Wardrobe Center. Offer personalized referrals to community resources to ensure a holistic approach to career development.
● Job Search Navigation Support
Provide one-on-one coaching and facilitate workshops designed to develop job search strategy skills Collaborate with local employers, employment agencies, and chambers of commerce to connect participants with job openings in their desired field of interest.

Includes connecting participants to hiring events, career fairs, and networking opportunities to enhance participants' chances of securing employment and establishing a sustainable career path.
● Ensure Long-Term Success through Follow-Up Services
Provide follow-up support for at least 12 months post-program to ensure participants are maintaining employment and progressing in their careers. Career Navigators will reach out to clients quarterly to check-in on employment status, continued or new barriers and additional skill development needs. Offer continued access to workshops, career coaching and linkages to community resources to address challenges and encourage ongoing career development.
● Incentives
Participants who complete significant milestones will receive an incentive in the form of a $125 gift card. Milestones include initial employment during the contract year, sustained employment at the second and fourth quarters post exit. Incentives are used to motivate participants to achieve their goals and maintain consistent employment.

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By achieving these objectives, the Rebuilding Careers Program for Young Adults will help underserved youth in Santa Ana overcome barriers to employment and education, providing them with the skills, experience, and support necessary for long-term career success.

3. Population
A. Working Wardrobes will serve a total of 20 youth through the Rebuilding Careers Program for Young Adults. These participants will be out-of-school youth, ages 16-24, who face significant barriers to entering the workforce.

B. The youth served will be between the ages of 16 and 24. Youth ages 18 to 24 will primarily be placed at off-site host agencies for work experience to help remove any barriers partners may have in working with under aged youth. Youth ages 16-24 will be eligible to gain work experience at Working Wardrobes social enterprise locations.

C. In addition to meeting WIOA youth eligibility requirements, Working Wardrobes will ensure that at least 25% of the total participants are either justice-involved, homeless and/or foster youth. In addition, participants must demonstrate a commitment to full engagement with the program. This will be assessed through their participation in an initial intake assessment and program orientation, which will ensure they understand the program's requirements and are prepared to benefit from the services offered.

D. Working Wardrobes will identify prospective participants by leveraging its extensive network of referral partners, including mission-aligned organizations serving transitional-age foster youth, youth experiencing homelessness, and justice-involved youth. These partners will help ensure that eligible youth, who require additional support to succeed in both their educational and employment goals, are referred to the program. Additionally, Working Wardrobes will recruit prospective participants through its core Rebuilding Careers workforce skills training program, identifying youth seeking to enroll in its services who would benefit from this specialized support. To further extend outreach, Working Wardrobes will continue to collaborate with OC Probation and Parole established through Working Wardrobes’ current contract with the City of Santa Ana, the Prison to Employment, P2E program to engage probationary youth, as well as outreach to sober and transitional living centers like HealthRight 360 and Nancy Clark (The Recovery Center). The organization will also seek referrals from existing youth-serving partners with established relationships, like Sunburst Academy, an alternative, military-based educational program that works with low-income youth, OC Department of Education ACCESS programs, Youth Guidance Center and Simon Scholars Foundation that offers leadership programs for youth, all of which have received workforce readiness services from Working Wardrobes.

Recruitment efforts will be focused on the recognition that Working Wardrobes has identified out-of-school youth as an underserved population, as many fall outside the services of existing youth program collaborators. While many of Working Wardrobes’ youth-focused community partners serve in-school youth, some young people are left without support when they no longer qualify for or are not a good fit for these programs. A direct referral to an alternative EXHIBIT 2

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program like Rebuilding Careers for Youth enables partners to connect out-of-school youth to comprehensive case management services, providing the support needed to achieve their career goals.

E. The Career Navigator will recruit the targeted youth populations through participation in OC PACT (Parole and Community Team) meetings, engagement with the Youth Council Network, monthly community tours, attendance at resource fairs, and program presentations to new and existing community partners. Working Wardrobes will create outreach flyers marketing the program and share them with over 185 referral partners.

F. Included as Attachment J is a Letter of Support from Simon Scholars. Although Simon Scholars primarily serves in-school youth, they can speak to the benefits their clients have experienced after participating in similar programming, including wardrobing services, and workshops.

G. Working Wardrobes' recruitment plan to enroll 80% of youth by the 2nd quarter of the program (December 31, 2026) includes a multi-faceted approach: participation in OC PACT meetings, engagement with the Youth Council Network, monthly community tours, attendance at resource fairs, and program presentations. Referral forms will be accepted from partners or through self-referrals. Staff will conduct a screening phone call to evaluate basic eligibility.

Eligible youth will then be invited to an orientation session with the Career Navigator, where they will learn about the program and complete the pre-application intake forms.

4. Assessment
A-B. A multi-step assessment process will be implemented to ensure a comprehensive evaluation of each youth participant. The TABE assessment will be completed prior to enrollment, with approval from the Service Navigator. After enrollment, additional career assessments will be conducted using O*Net Interest Profiler by the Bureau of Labor Statistics and Eureka.org, including tools like True Colors and Micro-skills assessments. These assessments will evaluate soft and hard skills, career interests, and learning styles to better match participants with suitable training and career pathways. Upon enrollment, clients will have the opportunity to contact a volunteer Career Coach who will assist them in taking the additional career assessment. For youth who know what job and/or industry they are interested in, they will be offered the O*Net Interest Profiler. This resource offers a deep dive into specific jobs based on the results of the assessment that include skills and training requirements, common job duties, median salary range by location and local training programs.

For young adults that need more direction, they will be offered other assessments like True Colors and Micro-skills. Once complete, the Career Navigator will help youth explore career pathways and set goals. Using the Eureka platform, participants will take assessments to gauge their work and communication styles, identifying natural skills despite limited work experience.

Clients will have access to the platform throughout the program to complete additional assessments.

C. Youth, especially those from low-income households and underserved communities, face significant barriers to employment that limit their access to opportunities compared to their EXHIBIT 2

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more advantaged peers. These challenges include limited exposure to high-demand career pathways, economic instability, and lack of resources, making it hard to pursue stable employment. Limited access to post-secondary education and family knowledge about higher education and vocational training add further obstacles, leaving many without the tools or guidance to improve job prospects. The absence of career mentorship compounds these issues, leaving young adults without role models to navigate the job market. These systemic barriers prevent youth from securing stable, well-paid jobs, perpetuating cycles of underemployment, economic hardship, and reduced social mobility. Over time, this increases reliance on public assistance and limits upward mobility, creating a cycle difficult to break without targeted interventions.

D. To address the barriers youth face, Working Wardrobes draws on its extensive experience serving underserved populations, with nearly half of its clients being youth. Core services offered to both youth and adult clients include one-on-one career assessments, personalized employment plans, resume building, job search strategies, and connections to secondary education, skill-based certifications, and life skills training. These services are delivered at the Career Success Center in Santa Ana, supported by trained Career Navigators, volunteer Career Coaches with HR/hiring experience, and Job Developers who help clients build the skills and confidence needed for successful job searches. The organization’s paid Work Experience (WEX) program is in early development, with a pilot program showing positive impacts for clients.

Working Wardrobes integrates these services and WEX programming into the Rebuilding Careers Program for Young Adults, providing targeted support to help out-of-school youth overcome barriers and enter pathways to quality, living-wage employment.

5. Paid Work Experience
A. The Rebuilding Careers for Young Adults program will provide participating Santa Ana out-of- school youth with valuable paid work experience. The program will utilize Working Wardrobes’ social enterprise division—including The Hanger Outlets, the Donation Center, and the Career Success Center—to offer in-house work experiences in retail, logistics, customer service, and operations, aligned with participants' interests. We will also offer office administrative experience with opportunities at our Career Success Center as Front Desk Attendants.

Working Wardrobes will offer participants up to 120 hours of paid work experience, including 10 hours of paid workforce training for up to 10 participants.

The Career Navigator will provide each host site with clear learning objectives and guidelines focused on helping youth develop transferable soft skills, such as teamwork, problem solving, communication, decision making, and time management. Additionally, the Career Navigator will support participants by facilitating informational interviews with both entry-level and managerial staff at work sites, giving them deeper insights into skill-based roles and potential career pathways the paid work experience can lead to.

Host sites will provide participants with 80 hours of project-based work, either independently or as part of a team. Each youth will receive constructive feedback from their host site supervisor at two key stages:

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1. A midpoint evaluation to identify strengths and areas for growth.

2. A final evaluation to assess overall performance and development.

Participants will also complete a self-assessment at the end of their internship, reflecting on their personal growth, performance, and the overall internship experience.

D. Working Wardrobes will prioritize pairing participants with paid work experience opportunities that align with their interests and are relevant to the WIOA-approved, skill-based certification and training programs they are or planned to be enrolled in. The Career Navigator will conduct assessments and collaborate with youth participants to identify their career interests. The Career Navigator will also perform targeted outreach to employers in industries that complement these interests, as well as related certification pathways.

E. As previously noted, prospective host site partners may include regional hospitals, logistics companies, and IT service providers. Attachment K outlines the affiliations of Working Wardrobes' Board of Directors, who will be engaged to arrange worksite opportunities within their respective workplaces. Additionally, Working Wardrobes will leverage the Supportive Mentors that have volunteered to participate through the B-Unbound platform that offers career exploration opportunities to Working Wardrobe clients These individuals span from a variety of industries including healthcare, finance, and entrepreneurial businesses.

F. Working Wardrobes has established partnerships with several employers and is in the process of finalizing commitments to this project. While letters are not available for inclusion at the time of this submission, they can be provided upon receipt of the Notice of Intent to Award.

G. Working Wardrobes’ Work Experience policy is included in this submission as EXHIBIT I.

6. Alternative Secondary School Services
A-B. Not applicable to the Rebuilding Careers Program for Young Adults. However, Working Wardrobes is able to provide referrals to OCDE ACCESS programs by leveraging its existing partnership. The organization has been providing four Career Success Weeks per year for the past three years as part of this collaboration. These Success Weeks consist of a 4-part workshop series and a wardrobe experience, with one of the weeks held at Sunburst Academy, a military- based alternative education program. Working Wardrobes can make referrals to both of these programs to further support the youth served.

Preparation for Postsecondary Education and Training
A. The Rebuilding Careers for Young Adults program equips participating youth with the skills and resources necessary for high-wage careers through career exploration, mentorship, and connections with Supportive Adults in high-demand sectors. Through these mentors, participants will be exposed to industries offering an average starting wage of $23/hour and long-term growth potential, including healthcare, IT, manufacturing, hospitality, and logistics.

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demand fields, such as construction, manufacturing, IT, culinary arts, and transportation, leading to the attainment of a postsecondary credential or secondary school diploma. These programs will provide up to $5,000 in tuition assistance to cover costs like tuition, tools, clothing, and equipment. The Career Navigator will assist participants in selecting and enrolling in the appropriate certification programs, offering support through facility tours and enrollment sessions. If a GED is required but not yet obtained, the Career Navigator will connect participants to alternative education programs, such as those through Santa Ana Community College Continuing Education, to ensure they meet enrollment prerequisites.

B. The Career Navigator will assist participants in identifying and enrolling in WIOA-approved postsecondary credential or secondary school diploma programs that align with their career goals. Through its other City of Santa Ana-funded contract (Prison to Employment program), Working Wardrobes has successfully helped clients enroll in programs at institutions such as North Orange County Education (NOCE), Santa Ana College, Healthstaff Training Institute, H.B.

CDL Training (Driving School), CTM Welding Training & Certification, and more. Working Wardrobes will leverage these established partnerships to identify suitable programs for out-of- school youth.

C. The Career Navigator will work with participants to create individualized employment plans based on each youth's career interests, strengths and assessments. For clients uncertain of their career path, the program will provide access to the B-Unbound platform (b-unbound.org), connecting participants with volunteer mentors from high-demand industries. Mentorship activities between participants and B-Unbound Supportive Adults include:
● Informational interviews.
● "A day in the life" workplace tours and job shadowing. ● Passion and skill-building exercises.

Upon being matched in the B-Unbound platform, participants will have six months to access the platform and request up to 5 mentorship connections. The Career Navigator will ensure the mentorship is a good match and assist with navigating the platform, coordinating meetings, and fostering connections. Supportive Adults working with minors will undergo a background check before starting mentorship activities.

D. The Rebuilding Careers for Young Adults program prepares youth for postsecondary education and training through:
● Workforce Readiness Training: Offering critical skills like time management, communication, professionalism, resume, job search and interviewing skill building. ● Mentorship and Networking: Connecting youth to volunteer HR-subject matter expert Career Coaches and industry mentors through B-Unbound who can guide them in selecting the right educational pathways, such as certifications or degrees. ● Application and Enrollment Support: The Career Navigator helps youth identify appropriate education or training programs and guides them through the application process.

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● Transition Assistance: Connecting participants with job leads and internships to ensure a smooth transition from education to employment.
● Connection to WIOA-Approved Certification/Training: Working with the Career Navigator to connect youth to WIOA-approved certification/skills-training providers for further education and training opportunities, as well as providing an average of $800 for tuition to cover these programs.

E. As part of the program, participants will receive support in identifying an industry or career path of interest and will work with their Career Navigator to find relevant WIOA-approved skill- based training opportunities for enrollment. The Career Navigator will collaborate with the WIOA Service Navigator to confirm pre-approved certification programs. This will include but not limited to certifications like, Clinical & Administrative Medical Assistant, Dental Assistant, Truck Driving Certification, CompTia+ Certification. Each youth will have an average of $800 allocated within the program budget to cover certification costs. If the cost of the program exceeds the budgeted amount, Working Wardrobes will partner with WIOA to explore additional funding opportunities to cover the difference including scholarships and Pell Grants.

Participants may enroll in and earn certificates during the program while gaining paid hands-on experience aligned with their interests and strengths, with some potentially enrolling in additional training following the conclusion of their paid work experience.

F. Research supports that the industries to be targeted by the program are among the fastest- growing in the U.S. with strong job prospects:
● Healthcare: Expected to add 2.4 million jobs by 2029 (Bureau of Labor Statistics, 2021). ● IT: Demand for skilled workers expected to grow by 11% from 2019 to 2029 (Bureau of Labor Statistics).
● Manufacturing: Advanced manufacturing and automation are driving demand for skilled workers.
● Hospitality & Tourism: Offering robust opportunities, especially in customer service, management, and logistics roles.

G. Letters of Intent from training agencies are not applicable, as the program will refer participants to training programs but will not formally partner with them.

8. Tutoring
For youth who are identified as basic skills deficient (scoring 8.9 or below on the TABE or CASAS assessments), the Rebuilding Careers for Young Adults program will refer them to tutoring or remedial training services as required by WIOA guidelines. Specifically, the program will connect youth to the North Orange Continuing Education (NOCE) Basic Skills & Learning Center, which offers academic support, including free tutoring in reading, writing, and math. NOCE’s services are well-suited to meet the needs of youth seeking to improve their foundational skills in preparation for career training and post-secondary education.

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In addition to NOCE, the Rebuilding Careers for Young Adults program will leverage its existing network of local resources, such as the OCDE Access program, to provide further academic support where necessary. This partnership will allow the program to ensure that all youth have access to tutoring resources that are aligned with their individual needs and learning styles. The Career Navigator will support youth throughout the tutoring process, helping them navigate enrollment and access the appropriate resources. The Career Navigator will work closely with tutors and educators to track progress and ensure that youth are receiving the necessary support to overcome academic challenges. By connecting participants to these tutoring resources, the Rebuilding Careers for Young Adults program ensures that all participants are well-equipped with the literacy and numeracy skills needed to succeed in training, education, and future employment opportunities.

9. Mentoring
I-J. The Rebuilding Careers for Young Adults program will offer mentoring support through both the B-Unbound mentorship platform and in-person career coaching. As previously outlined, B- Unbound connects participants with adult mentors, known as “Supportive Adults,” in their fields of interest. Facilitated by the Career Navigator, the platform allows youth to engage in job shadowing, mock interviews, guided discussions, and personalized career coaching through up to five interactive sessions. These sessions will provide insights into industries such as healthcare, finance, and green jobs, helping youth develop professional skills and connections for workforce navigation.

Participants will also receive ongoing support from volunteer Career Coaches with HR-related experience, who assist with resume building, interview skills, labor market analysis, and career opportunity identification. The program’s Job Search Lab at the Career Success Center in Santa Ana offers essential resources like computers and printers, enabling youth to create resumes, research job opportunities, and access the tools necessary for a successful job search.

K. For youth facing challenging obstacles such as family dysfunction, mental health issues, homelessness, low self-esteem, probation, gang involvement, or parenting issues, the program will provide holistic support by connecting them to specialized resources. The Career Navigator will assess each participant's individual needs and, where appropriate, refer them to local organizations offering targeted services. These may include behavioral health organizations such as NAMI-OC, Peer Voices, and Waymakers, which provide mental health support, as well as programs like H.I.R.E, which serves justice-involved youth with reintegration and personal development resources.

L. The Rebuilding Careers for Young Adults program will also provide referrals for drug and alcohol counseling. Participants who need support in this area will be connected with sober living facilities, such as Nancy Clark, as well as detox services. The program maintains a network of nonprofit case managers who collaborate and share resources through online platforms and monthly meetings, ensuring that youth have access to the comprehensive guidance and counseling they need to address any substance use challenges they may face. By offering these EXHIBIT 2

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support services, the program ensures that youth are not only prepared for their future careers but are also equipped to overcome personal challenges and thrive in all areas of their lives.

10. Workshops
M. The Rebuilding Careers for Young Adults program will offer a variety of workshops designed to help youth build the skills necessary for career success. These workshops will be provided through a combination of in-person sessions and self-paced learning, offering a comprehensive learning experience. The workshops will be conducted at the Working Wardrobes Career Success Center in Santa Ana, with a total of 10 workshops scheduled throughout the one-year program term, divided into two cohorts (5 workshops per cohort). Each cohort will participate in a series of five signature workshops including You’ve Got Skills/O*Net Career Assessment, Navigating Success in the Workplace, Power of Your Image (professional branding), Resume/Job Search Strategies, Mock Interviewing. In addition, participants will have access to two self- paced learning exchange platforms that offer additional workforce readiness and professional skill building courses. Participants will have access to both the FUBU and Accenture sponsored platforms that offer on-demand workforce related virtual courses that support the in-person workshop topics for the duration of the program. Through these workshops, the Rebuilding Careers for Young Adults program will provide youth with a well-rounded skill set to excel in both their personal and professional lives, these workshops will include:
● Financial Literacy/Budget Management: In partnership with board members and volunteers from local banks like U.S. Bank and Sunwest Bank, the program will offer workshops covering essential financial skills, such as budgeting, credit management, saving for the future, and navigating financial challenges. These sessions are designed to empower youth with the knowledge to manage their finances responsibly, setting them up for economic independence and long-term career success. ● Analytical Skills at the Workplace: Participants will gain valuable analytical skills needed in the workplace through access to the self-paced WW Learning Exchange curriculum, sponsored by Accenture and FUBU. This curriculum will focus on developing critical thinking, problem-solving, and decision-making abilities, all of which are essential for success in any industry. Participants will have the opportunity to build these skills in a flexible, self-paced learning environment, equipping them to tackle complex workplace challenges with confidence.
● Professional Communication Skills (Verbal, Written, Physical): All workshops will incorporate activities to enhance both written and verbal communication abilities.

Additionally, participants will have access to the self-paced WW Learning Exchange curriculum, sponsored by Accenture and FUBU, providing further opportunities to build professional communication skills for success in the workplace. ● Navigating Success in the Workplace: The objective of this workshop is for participants to learn the necessary life skills needed when joining a new workplace. This includes understanding employer and employee expectations, identifying new work culture EXHIBIT 2

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norms like communication styles and appropriate behavior, and managing outside life experiences while learning a new role or job.
● Power of Your Image: The goal of this workshop is to help participants distinguish between personal and professional image and understand how each impacts both the job search process and success after securing a position. Participants will learn the components of a professional brand, including appearance, communication style, online presence, reputation, and work ethic. In this session, they will craft an Elevator Pitch, practice professional greetings, and learn basic professional language skills. ● You’ve Got Skills/O*Net Interest Profiler: The objective of this workshop is for participants to learn the difference between soft vs. hard skills and begin to self-identify their natural and learned talents as a starting point to crafting the Story of You! Participants will be introduced to the ONet Online website that utilizes national and local data from the U.S. Department of Labor to provide comprehensive information about a vast range of positions and industries. A facilitator will help participants navigate the website, use the ONet Interest Profiler to take a career assessment, and select and deep dive into their top 3 career interests. ● Building Blocks of a Resume/Job Search Strategies: The objective of this workshop is to learn the purpose of a resume, identify the key sections, learn how resumes are processed in an applicant tracking system (ATS), and start to draft the professional summary or objective using the self-identified skills from the previous workshop.

Participants will gain practical tips for creating clear, concise resumes that are effectively written and optimized for success when submitted through applicant tracking systems.

Participants will also learn strategies for researching desired careers, maximizing network opportunities, and setting up effective communication systems. ● Mock Interviewing: The objective of this workshop is to learn the basics of how to prepare before, during, and after an interview, including developing success stories for some of the most commonly asked behavioral interview questions. In this session, participants will use tools like the S.T.A.R. method to write stories utilizing their previously identified skill set, elevator pitch, and work/life experiences. This interactive workshop will provide a supportive space for participants to practice interviewing, utilizing an interview feedback form that offers the interviewer the opportunity to provide constructive feedback on presentation, communication, and storytelling.

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11. Will your agency provide Civic Engagement or Leadership Development A. Working Wardrobes will not provide a civic engagement opportunity or leadership development opportunity for participating youth.

12. Supportive Services
The program will offer a range of supportive services to ensure youth have the necessary resources to overcome barriers and achieve their employment goals. These services include transportation assistance, such as gasoline debit cards and bus passes, to help participants attend interviews, job training, and other employment-related opportunities. Additionally, the program will provide support for essential incidental needs, such as obtaining identification or credentials, covering background check costs, and professional grooming. These services are designed to help participants address barriers to employment, making it easier for them to secure and maintain jobs.

To further support their professional growth, each participant will participate in Working Wardrobes’ signature wardrobing experience in a department like Wardrobe Center located in the Career Success Center. Youth will receive an interview ready, business casual outfit, top, bottom, shoes, and accessories, to help them make a strong impression during interviews and on the job. The Wardrobe Specialist will provide personalized assistance, ensuring that each participant receives an outfit that aligns with their professional needs and goals. These supportive services are crucial for empowering youth to succeed in their career pursuits.

Working Wardrobes’ Supportive Service Policy will be included as EXHIBIT J.

13. Incentives
A. To support youth retention and goal achievement post-program exit, Working Wardrobes will offer incentives. Participants may receive incentives valued at up to $125 per milestone with a maximum of $375 per participant in the form of gas cards, grocery cards (such as Walmart or similar retailers), or general prepaid Visa gift cards upon completion of verified program activities. successful initial employment, 2nd and 4th quarter post exit employment.

B. An Incentive Policy is attached to this submission as Exhibit K.

14. Follow-Up Services
A. All youth participants will receive follow-up services for a minimum of 12 months after exiting the program (option to complete virtual or in-person at Career Success Center). This begins with an exit survey that includes a client testimonial and feedback about services upon exit. After exiting the program, clients will still receive updates about job opportunities, resources and Working Wardrobes events through a period email distribution newsletter.

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ins for one year post exit. These services will be personalized to each participant's needs and include ongoing support to help them maintain employment, pursue further education, and address any challenges they may encounter in their career journey.

B. The Career Navigator will continue their case management and serve as the primary point of contact, offering personalized coaching and mentoring throughout the follow-up process. This continuous support will help participants address any challenges they encounter in areas such as job retention, career advancement, and further education. By offering tailored guidance, the Career Navigator will ensure that participants stay on track to achieve their long-term goals.

This may include connecting them to resources that will help remove newly discovered barriers to completing certification programs and/or maintaining employment.

C. Each participant’s progress will be assessed post-program through quarterly follow-ups. The Career Navigator will track key performance indicators, including employment status, job retention, career advancement, and continued education. A series of questions will be asked during the quarterly follow-ups and captured in Working Wardrobes’ CRM, Casebook.

Participants will be engaged in goal-setting discussions during each follow-up, ensuring that they are progressing toward their personal and professional milestones. The program will ensure that all youth meet the performance indicators by providing consistent support and adjusting services as needed to address challenges or barriers that may arise during the follow- up period.

D-E. To encourage youth retention and goal attainment, the program will provide incentives during the follow-up period. Each participant will be eligible for a $125 incentive in the form of a gift card once they secure initial employment during the contract year. To receive the incentive, participants must submit documentation that includes a completed form, a client testimonial, and a copy of their first paycheck. Additional incentives of up to $125 will also be made available to participants who maintain employment during the 2nd and 4th quarter follow- up post exit. These incentives are designed to reinforce positive outcomes and encourage continued engagement in the program.

Additionally, participants will maintain access to Working Wardrobes' ongoing services as needed, such as career coaching, workshops, and self-paced learning platforms. By providing continued access to these resources, the organization ensures that participants receive the necessary tools and guidance to thrive in their professional lives, leading to sustained success in their careers.

15. WIOA Performance Indicators

1. Percent of participants in education or training or unsubsidized employment during the 2nd quarter after exit.

Working Wardrobes anticipates that 68% of the 20 enrolled participants will participate in education, training or unsubsidized employment during the 2nd quarter after exit. A 12-month follow-up ensures outcomes are tracked during the critical second quarter after program exit.

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Ongoing contact and wraparound support help participants successfully retain employment or remain enrolled in education or training programs.

2. Percent of participants in education or training or unsubsidized employment during the 4th quarter after exit.

Working Wardrobes anticipates that 62% of the 20 enrolled participants will participate in education, training or unsubsidized employment during the 4th quarter after exit. Employment tracking will continue through the fourth quarter, with ongoing support from the Career Navigator. Employment status and education progress are monitored, and assistance is provided for career advancement, certifications, or reemployment as needed.

3. Document the median earnings of participants in unsubsidized employment during the 2nd quarter after exit.

Wage data will be collected through participant surveys, and state wage records. This information allows accurate calculation of median earnings for participants employed during the second quarter after exit, helping assess program impact and inform future employer partnerships.

4. Percent of participants who obtain a recognized postsecondary credential or secondary diploma during participation or within 1 year after exit.

Working Wardrobes anticipates that 62% of participants who are enrolled in postsecondary credential or secondary diploma programs will attain certification and/or diploma. Staff assist participants with exam preparation, credentialing application processes, and provide barrier removal (e.g., transportation, childcare referrals). Working Wardrobes’ follow-up services extend credential support beyond program exit to maximize postsecondary attainment.

5. Percent of participants achieving measurable skill gains during education/training leading to a credential or employment.

Working Wardrobes anticipates that 59% of participants who are enrolled in postsecondary credential or secondary diploma programs will achieve measurable skill gains during education/training. Skill gains are tracked using as least one of the five MSG measures, which include Educational Functioning Level, secondary school diploma, transcript/report card, progress towards established milestones and skills progression. Each participant’s measurable skills gains are documented to ensure progress toward employment or credentialing goals.

6. Effectiveness in serving employers.

Working Wardrobes’ builds relationships with local businesses to align employer workforce needs with participant skills. The organization will collect feedback on job readiness, retention, and satisfaction, using it to adjust training offerings and develop sector-specific opportunities based on labor market trends.

Working Wardrobes will measure its effectiveness in serving employers by tracking the retention of employer partnerships and feedback received. Specifically, the organization will assess retention in the 2nd and 4th quarters after exit through quarterly check-ins conducted EXHIBIT 2

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by the Career Navigator, who will also gather employer feedback. Additionally, Working Wardrobes will monitor how many participants secure employment with the same employer either during their work experience or upon hire.

17. Fiscal Competency
A-B. Working Wardrobes uses a structured process to capture and report fiscal data. All financial transactions are logged into a centralized financial management system. The Career Navigator documents and tracks requests, approvals, and payments for Participant Tuition Assistance, Incentives and Supportive Services. This ensures that all payments comply with budget limits and eligibility criteria. Financial reports are generated regularly to assess expenditure trends, track costs, and maintain transparency. Working Wardrobes’ HR management system, Rippling will be used to track time, attendance and compensation for the WEX program. A copy of the organization’s procurement policies and procedures will be provided as Attachment P.

C. Working Wardrobes ensures compliance with government-funded programs by understanding all contract requirements, maintaining accurate documentation, and conducting regular reviews of service and financial data. The organization uses financial management software to track expenditures, monitor budgets, and ensure fiscal accountability. Program staff follow strict guidelines for approving and issuing payments. During the paid work experience, participants will track time and attendance through a system aligned with Working Wardrobes' financial management system. They will also use the HR management system, Rippling to access their schedule, sign in/out, and track bi-weekly compensation. Employer host sites will use a physical timesheet, which is reviewed, signed, and returned weekly. The Career Navigator will regularly review these logs for accuracy, and a form is provided for tracking and submitting weekly hours for approval.

D. The invoicing process starts with the Career Navigator submitting payment requests, which are reviewed by the Client Services Manager and approved by the Director of Client Services.

Payments are made via company checks or credit cards to service providers. Program staff, trained in financial management, ensure compliance with fiscal guidelines. The Chief People and Operations Officer oversees accounting, with invoicing handled by a Senior Accountant and supported by a fractional CFO from Fohrman & Fohrman, Inc. The Career Navigator, Wardrobe & Inventory Specialist, and Career Development Coordinator manage data collection and internal monitoring, collaborating with the accounting team to resolve any issues.

E. Working Wardrobes maintains financial stability through a diversified funding base, including individual donations, corporate sponsorships, foundation grants, and earned income from program services. This model ensures resilience and the ability to continue providing high- quality services despite fluctuations in WIOA funding.

F. A significant amount of the budget is allocated to youth services, including paid work experience, training, supportive services, and tuition support. The remaining funds cover overhead and administrative costs. All expenditures are monitored for alignment with program EXHIBIT 2

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goals. Payments for Participant Incentives, Tuition and Supportive Services, including gasoline debit cards and bus passes, are issued via company checks or credit card to service providers, with no direct payments to participants. Supporting documentation, such as a supportive service request form signed by the participant, Career Navigator and Client Services Manager, invoices and receipts, will be collected and reviewed for compliance with program guidelines.

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Working Wardrobes
Work Experience (WEX) Policy Guide
Effective 7/1/2025
Purpose
Working Wardrobes offers learning opportunities through Work Experience (WEX) to support participants in building practical skills and confidence in a real-world work setting.

WEX is designed for individuals with limited work history, employment gaps, or financial instability, and complements our Job & Career Support services while participants continue their active job search.

Wo
rk Experience activities may include:
• Int
ernships and job shadowing.
• On-the-job training opportunities.

WEX services are provided in accordance with active grant contracts, which define eligibility, target populations, and applicable program regulations and guidelines Participant Compensation and Available Hours
Participants engaged in WEX shall be compensated at minimum California minimum wage or more depending on funding availability.

Participants will complete an average of approximately 240 hours of Work Experience (WEX), unless otherwise specified by the applicable contract or funding requirements.

Allowable Expenditures
If contract allows funds may be used to pay wages and staffing costs for the development and management of work experience.

Allowable expenditures beyond wages may include the following:
• Staff time spent identifying potential work experience opportunities. • Staff time working with employers to develop the work experience. • Staff time spent working with employers to ensure a successful work experience. • Staff time spent evaluating the work experience.
• Classroom training or the required academic education component is directly related to the work experience.
• Orientation sessions for participants and employers.

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• Participant recruitment and screening for work experience eligibility. • Assessment of participant readiness for work experience placement. • Creation and documentation of the individual work experience plan. • Preparing the participant for workplace expectations and soft skills. • Ongoing case management and coaching during placement. • Addressing attendance, performance, or behavioral concerns. • Communication with participant regarding schedule, expectations, and progress • Monitoring participant progress and documenting case notes. • Follow-up support to help transition from WEX to unsubsidized employment.

Positions Available
Front Desk Ambassador: Plays a key role in maintaining the integrity of our office space and ensuring that guests have a positive first impression each time they visit. Also plays a key support role for staff with various administrative and clerical tasks Retail Operations Coordinator: Provides excellent customer service, assists with merchandising, and supports store operations across multiple locations.

Donation Center Operations Coordinator: Keeps the Donation Center running smoothly, handles inventory, maintains quality control, and supports daily operations.

Staff Roles
Client Services Manager: Oversees implementation and launch of the Work Experience (WEX) program; coordinates across staff to ensure readiness, compliance, and timely onboarding of participants; supports staff throughout the placement process; and provides guidance and coaching to promote successful participation and positive workplace engagement, and participates in periodic check-ins and evaluations of participant progress Career Navigator: Determines eligibility and supports program enrollment; assesses appropriateness and readiness for Work Experience (WEX); develops and updates the Individual Employment Plan (IEP); coordinates and facilitates the participant introduction with the worksite supervisor; and provides ongoing guidance to help the participant navigate workplace expectations, engagement, and success.

People Operations Manager: Supports the application and initial interview process; completes employment onboarding requirements, including I-9 verification and new hire documentation; and serves as the HR point of contact for worksite supervisors regarding personnel policies, workplace concerns, and compliance-related matters.

Site Manager:Provides day-to-day supervision and training to the participant; assigns tasks that support skill development and exposure to workplace expectations; verifies participant attendance and approves timesheets; communicates performance, attendance, or EXHIBIT 2

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workplace concerns to Working Wardrobes staff; and participates in periodic check-ins and evaluations of participant progress.

Participant Onboarding

1. Participants complete workshop and coaching appointments for multiple workforce readiness services including Soft Skills, Resume, and Interview Practice along with a professional wardrobing appointment.

2. The People Operations Manager opens available WEX positions and invites appropriate participants to apply. The People Operations Manager conducts a brief phone screening and shares feedback with the Career Navigator regarding placement readiness.

3. The Career Navigator schedules a meet-and-greet with the worksite supervisor, which serves as the final placement interview.

4. The participant is moved to hired status and completes any required background check

5. Once cleared, the participant attends program orientation, which includes:
a. Staff orientation and workplace expectations
b. Navigating Success in the Workplace workshop
c. Timekeeping platform setup
d. Required online trainings

6. The participant connects with the worksite supervisor to confirm schedule, start date, and reporting expectations prior to the first day of training.

Documentation
Working Wardrobes documents each participant’s Work Experience (WEX) participation in its primary case management system, Casebook. Staff maintain a continuous record of the participant’s WEX journey, including training start and end dates, placement details, case notes, attendance patterns, and progress updates. Case notes document participant successes, skill development, and any concerns or barriers impacting participation.

For contracts that require reporting in an external system, such as CalJOBS, staff also enter required activities, services, and outcomes into the designated platform.

Timekeeping & Payroll
Participants record their hours by clocking in and out using Working Wardrobes’ staff timekeeping platform and by completing and signing timesheets.

Completion & Transition
Upon completion of Work Experience (WEX), staff evaluate skill development and support the participant’s transition to unsubsidized employment, continued job search, or additional EXHIBIT 2

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training as appropriate. Exit and follow-up services are documented in the primary case management system, Casebook, and in any external reporting platform required by the applicable contract.

Record Retention
All participant records are retained grant requirements and made available for monitoring.

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Working Wardrobes
Supportive Services Policy Guide
Effective 7/1/2025
Purpose
Supportive Services are provided to assist participants in overcoming documented employment- related barriers that prevent participation in program services, training, Work Experience (WEX), job search activities, or employment retention. Supportive Services are a temporary intervention and are not intended as general financial assistance.

Supportive Services:
• Must be directly connected to the participant’s employment or training goal • Must be documented in the participant service plan and case notes • Are provided on a case-by-case basis
• Are contingent upon funding availability and program eligibility • Are not an entitlement and are not guaranteed
Eligibility and Determination of Need
Working Wardrobes utilizes a holistic service approach that recognizes employment success is impacted by basic needs stability. Supportive services may be provided when a participant’s immediate needs to create a documented barrier to participating in program services, training, Work Experience (WEX), interviews, or employment.

Requests are evaluated on a case-by-case basis and must demonstrate a clear connection between the requested support and the participant’s ability to participate in their employment plan.

Supportive services may be approved when:
• A barrier to participation or employment is identified • The service directly enables participation in program activities • The participant is actively engaged in services
Supportive services may be denied when:

• The need is not related to employment participation
• The participant is not engaged in services
• Funding is unavailable
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Required Documentation and Justification Narrative
All supportive services must be fully documented and clearly connected to the participant’s employment plan. The Career Navigator must document the request in the participant’s service plan and case notes in Casebook and ensure the file demonstrates how the service supports participation in program activities, training, Work Experience (WEX), job search, or employment.

Each supportive service must include:
• Completed Supportive Service Request Form
• Written justification explaining the employment barrier • Approval signature
• Proof of payment/purchase
• Proof of receipt by participant, if required by contract o One-Time Waiver: Should a participant lose his/her receipt, they will be required to complete an applicant statement with all pertinent information. Should a participant lose a subsequent receipt, they will be penalized by not being able to obtain another supportive service for a 30-day period.
• Case note and service entry in Casebook, and in any external reporting platform required by the applicable contract
The justification narrative must explain:
• The employment barrier
• Why the barrier prevents participation or employment
• How the requested service resolves the barrier
• The expected employment activity or engagement following receipt of the service Types of Supportive Services
Allowable supportive services vary by contract. They may include, but are not limited to:

Transportation
• Gas cards or public transit passes
• Rideshare assistance when no reasonable transportation alternative exists • Automotive repair assistance necessary for transportation to employment or program activities (case-by-case review)
• Other transportation needs such as car registration, insurance payment, etc.

Employment Preparation and Work-Related Needs
• Interview clothing or required work attire not covered through wardrobing • Work shoes or safety equipment required for employment or WEX EXHIBIT 2

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• Required employment tools, supplies, or uniforms
• Fees for background checks, fingerprinting, or employment screening Documentation and Employment Requirements
• State identification cards or driver’s license fees
• Birth certificates or other required employment documentation • Testing or licensing fees required for employment
• Background checks
Training and Education Support
• Tuition assistance for approved short-term occupational training • Certification exam fees
• Required course materials, books, or supplies
Basic Needs Related to Participation
• Limited food assistance when food insecurity prevents attendance or participation • Hygiene or grooming items necessary for interviews, work, or WEX participation • Minor household or utility assistance when loss of service would prevent participation Other Barrier-Removal Services
• Other supportive services determined necessary to enable participation in the participant’s employment plan

Staff Roles
Career Navigator
The Career Navigator is responsible for identifying and documenting participant need and initiating supportive service requests. Duties include:
• Assessing and documenting the employment-related barrier • Discussing alternative resources with the participant when appropriate • Completing the Supportive Service Request Form
• Providing written justification connecting the service to participation in program activities or employment
• Collecting required documentation and participant signatures • Obtaining invoice or estimate when applicable
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• Uploading the completed packet and supporting documentation to Casebook, and in any external reporting platform required by the applicable contract • Entering the appropriate service and case note in Casebook, and in any external reporting platform required by the applicable contract
• Obtaining proof of receipt from the participant
Program Manager
The Program Manager is responsible for review, approval, and processing of supportive services.

Duties include:
• Reviewing requests for completeness, eligibility, and funding availability • Approving or denying supportive service requests
• Purchasing approved items, issuing gift cards, or submitting check requests • Ensuring appropriate documentation is collected
• Submitting documentation for accounting and audit compliance • Recording the expense in the contract expense tracker Program Director
The Program Director provides oversight and additional authorization for higher-cost requests. • Reviews and approves supportive service requests exceeding $1,000 • Ensures requests are reasonable, necessary, and aligned with contract and program guidelines

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TO WHOM IT MAY CONCERN

Subject: Loss of receipts for gas purchase
I, __________________________________________________, have misplaced the receipt for

_________________________________ (type of purchase) at _________________________________ (store) issued to me for the month of ________________________________.

Date of Purchase: _______________________________________

Amount Spent: _________________________________________

I understand that I may be subject to sanctions imposed by Working Wardrobes as per its policies on supportive services.

Print Name: _______________________________________
Signature: ________________________________________

One-Time Waiver: Should a participant lose his/her receipt, they will be required to complete an applicant statement with all pertinent information. Should a participant lose a subsequent receipt, they will be penalized by not being able to obtain another supportive service for a 30-day period.

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Working Wardrobes
Incentives Policy Guide – Effective 7/1/2025
Purpose
Working Wardrobes provides participant incentives to encourage engagement, recognize progress, and reinforce achievement of key program milestones that support employment outcomes.

Incentives are not supportive services and are not intended to remove employment barriers or provide financial assistance. Instead, incentives are performance-based and awarded after completion of specific program activities aligned with employment readiness, education, and job placement.

Incentives:
• Are earned by completing defined program milestones
• Are provided after verification of completion
• Are contingent upon funding availability and program eligibility • Are not an entitlement and are not guaranteed
• Do not replace supportive services

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Eligibility
Participants must be enrolled and in good standing with the program to be eligible to receive incentives.

A participant is considered in good standing when they:
• Are actively participating in program services
• Maintain communication with staff
• Complete scheduled activities
Participants who are unsuccessfully exited, non-responsive, or dismissed from the program are not eligible for incentives.

Eligible Milestones
Incentives may be issued for successful completion of the following verified achievements:

Program Engagement
• Completion of enrollment and orientation process,
• Completion of any assessments, pre surveys as required by the program • Completion of Individualized Employment Plan
Employment Achievement
• Obtaining unsubsidized employment
Continued Verification of Employment
• Providing continued proof of employment based on contract guidelines and success measures
Education & Training
• Completion of secondary education (e.g., High School Diploma or GED) • Completion of an approved occupational training or certification program Program Completion
• Completion of the program exit interview (includes completion of any updating of documents, surveys assessments)
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Milestones must be verified and documented in Casebook and any required external reporting system prior to incentive issuance.

Documentation Requirements
All incentives must be documented and verified prior to issuance.

Each incentive must include:
• Verification of milestone completion
• Case note documenting the achievement
• Approval from the Program Manager
• Participant signature acknowledging receipt
• Copy or record of the incentive issued
• Entry in Casebook and any required external reporting platform

Types of Incentives
Incentives may be issued in the form of:
• Gas cards
• Grocery cards (e.g., Walmart or similar retailer)
• General prepaid Visa gift cards
The specific type and value of the incentive may vary depending on funding source and budget availability. Incentives are issued only after staff verify completion.

Staff Roles
Career Navigator
• Verifies participant milestone completion
• Documents achievement in Casebook and any required external reporting system • Requests incentive issuance
• Collects participant signature upon receipt
• Uploads documentation
Program Manager
• Confirms milestone verification
• Approves incentive issuance
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• Distributes gift card or prepaid card
• Maintains documentation for audit compliance
• Records the expense in the contract expense tracker
Program Director
• Provides oversight of the incentive program
• Approves incentive amounts exceeding standard program thresholds General Guidelines
• Incentives are subject to available funding and may change based on contract or program guidance.
• Incentives are provided only after milestone completion and cannot be issued in advance. • Incentives are not wages, stipends, or compensation for participation.

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Procurement Policy

1. Purpose
The purpose of this Procurement Policy is to ensure that Working Wardrobes conducts procurement activities in a transparent, ethical, and cost-effective manner while supporting our mission of helping people overcome barriers to gainful employment.

2. Scope
This policy applies to all purchases of goods and services made on behalf of Working Wardrobes, including those by employees, volunteers, and contractors.

3. Guiding Principles
● Integrity: All procurement activities must be conducted with honesty and fairness. ● Accountability: Staff must ensure that funds are spent responsibly and aligned with the organization's goals.
● Cost-Effectiveness: Purchases should offer the best value for money without compromising quality.
● Compliance: All procurement must adhere to applicable laws, regulations, and funding requirements.
● Sustainability & Diversity: Consideration should be given to environmentally sustainable products and diverse suppliers, including small, minority-owned, and women-owned businesses.

4. Procurement Process

4.1 Purchase Authorization
● Purchases up to $500 may be approved by department heads. ● Purchases between $501 and $10,000 require approval from the Chief People and Operations Officer.
● Purchases exceeding $10,000 require approval from the CEO.

4.2 Vendor Selection
● For purchases under $5,000, a single quote is sufficient. ● For purchases between $5,001 and $25,000, at least two written quotes should be obtained.
● For purchases exceeding $25,000, a formal Request for Proposal (RFP) process should be conducted.

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● Sole-source procurement is allowed only when justified and approved by leadership.

4.3 Conflict of Interest
● Employees and volunteers must disclose any relationships with vendors that could present a conflict of interest.
● Procurement decisions should be made objectively and in the best interest of the organization.

4.4 Contracting & Documentation
● All agreements must be documented in writing and signed by authorized representatives.
● Contracts over $10,000 should be reviewed by legal counsel. ● Records of procurement activities, including quotes and approvals, must be maintained for auditing purposes.

5. Vendor Management
● Vendors should be evaluated periodically based on performance, cost, and service quality.
● Long-term partnerships should be reviewed annually to ensure continued value and alignment with organizational needs.

6. Policy Review
This policy will be reviewed annually and updated as necessary to reflect changes in regulations, funding requirements, or organizational priorities.

Effective Date: January 1, 2025
Approved By: Derek Benson, Chief People & Operations Officer

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EXHIBIT B 1
YSPN MEMBER PERFORMANCE PLAN 2026-2027
Working Wardrobes

WIOA YOUTH POPULATION
Youth Population Ages # of Youth to be Served
In-School 16-18 0
Out-of-School (75% minimum) 16-24 20
TOTAL NUMBER OF YOUTH TO BE SERVED 20

PROJECTED ENROLLMENTS & EXPENDITURES
(NOTE: 100% OF YOUTH MUST BE ENROLLED BY 2ND QUARTER-DECEMBER 31, 2026) Quarter # of Enrollments
per Quarter Estimated Expenditures per Quarter
1st 10 $50,000
2nd (100% Enrollment Required) 10 $65,000
3rd $50,000
4th $35,000
TOTAL 20 $200,000

14 WIOA ELEMENTS
mark a “x” next to the elements provided in your
program

PERFORMANCE MEASURES
(Projected Benchmarks subject to change
Baseline=BL )

1. Tutoring, study skills training, dropout prevention
strategies

1. % of Participants who are in education/training,
or in unsubsidized employment during the 2nd
quarter after exit
Benchmark: 68%

2. Alternative secondary school services or dropout
recovery
x 3. Paid & unpaid work experience that have
academic and occupational components, which may
include: summer employment, pre-apprenticeship,
internships & job-shadowing, or On-the-Job training
(20% of funds must be used for this element)

2. % of Participants who are in education/training,
or in unsubsidized employment during the 4th
quarter after exit
Benchmark: 62%

x 4. Occupational skills training—priority for
recognized credentials aligned with sectors in
demand

3. The median earnings of Participants in
unsubsidized employment during the 2nd quarter
after exit
Benchmark: $4000
*Pending further State and Federal guidance.
x 5. Education offered concurrently with workforce
preparation activities

4. % of participants who, during the program, are
in education or training that leads to a recognized
postsecondary credential or employment AND
who are achieving measurable skill gains
Benchmark: 59%

*Pending further State and Federal guidance.

6. Leadership development, community service &
peer-centered activities
x 7. Supportive Services
x 8. Adult mentoring
x 9. Follow-up services for not less than 12 months
after exit (required)

5. % of Participants who obtain a recognized
postsecondary credential or secondary diploma
during participation OR within 1 year after exit
Benchmark: 62%

10. Comprehensive guidance & counseling drug &
alcohol, etc.
x 11. Financial literacy 6. Effectiveness in serving employers Benchmark: BL*

*Pending further State and Federal guidance.

12. Entrepreneurial skills training
x 13. Labor marker information-career awareness and
exploration
x 14. Activities to help youth prepare for and
transition to postsecondary education

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EXHIBIT C

COMPLAINT HANDLING

UNDER THE
Workforce Innovation Opportunity Act

Santa Ana Local Workforce Development Area
Revised May 20, 2019

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Table of Contents

I. Information Regarding Complaints 3
A. Nondiscrimination and Equal Opportunity Complaints 3

1. Policy Statement 3

2. Civil Rights 4

3. Nondiscrimination laws under WIOA 4

4. How to File Your Complaint 5
B. Criminal Complaints 6
II. General Procedures for Handling Non-Criminal Violations of the Act 6 III. Procedures for Handling Complaints at the LWDA Level 8 IV. Procedures for Handling Complaints at the State Level 12 V. Procedures for Handling Discrimination Complaints by Participants 15 VI. Procedures for Handling Disability Complaints by Participants 17 GLOSSARY OF WIOA TERMS 20

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I. Information Regarding Complaints

A. Nondiscrimination and Equal Opportunity Complaints

1. Policy Statement
In carrying out the purpose of the Workforce Innovation Opportunity Act (WIOA), the City of Santa Ana Local Workforce Development Area (LWDA) will establish programs to prepare youth and unskilled adults for entry into the labor force and to afford job training to those individuals facing serious barriers to employment. Every effort will be made to provide services necessary for eligible individuals to obtain productive employment.

In implementing WIOA, all contractors in the Santa Ana LWDA will foster equal opportunity and non-discrimination, as provided in State and Federal equal opportunity and non-discrimination laws including, but not limited to:

 Title VI of the Civil Rights Act of 1964
 Title VII of the Civil Rights Act of 1964
 The Age Discrimination Act of 1975, as amended
 Section 503 of the Rehabilitation Act of 1973
 Section 504 of the Rehabilitation Act of 1973
 Title IX of the Education Amendments of 1972
 Section 188 of the Workforce Innovation Opportunity Act of 2014

In keeping with our commitment, no individual shall be excluded from participation in, denied benefits of, subjected to discrimination under, or denied employment, in the administration or of in connection with any WIOA funded program because of race, color, religion, sex, national origin, age, disability, or political affiliation or belief.

Participation in programs and activities financially assisted in whole or in part under WIOA shall be open to citizens and nationals of the United States, lawfully admitted permanent resident aliens, lawfully admitted refugee, parolees, and other individuals authorized by the Attorney General to work in the United States.

No individual will be intimidated, threatened, coerced, or discriminated against because of filing a complaint, furnishing information, or assisting or participating in any manner in an investigation, compliance review, hearing or any other activity related to the administration of WIOA.

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Administration responsibility for this Equal Opportunity/Affirmative Action (EO/AA) Program is delegated to the Equal Employment Opportunity (EEO) Officer for the Santa Ana local Workforce Development Area. Equal opportunity and non- discrimination, however, will only be achieved through leadership and implementation of a viable Affirmative Action Equal Opportunity Program.

2. Civil Rights
No one applying for or enrolled in the Workforce Innovation Opportunity Act (WIOA) programs may be discriminated against because of race, color, creed, disability, national origin, sex, age, political affiliation, or beliefs.

This means that – for any of the characteristics listed above:

 You may not be denied the opportunity to enroll in WIOA.  No benefits or services may be denied you for discriminatory reasons.  You may not be segregated or treated any differently from other applicants or participants, while you are being registered, interviewed, counseled or tested; or while you are working or attending classes as part of the program.  You must be provided an equal chance to use all facilities available in the program.
 Fair employment practices must be provided to all staff with regard to recruiting, hiring, transferring, promotions, training, compensation, benefits, layoff, and termination.

You have the right to make a complaint if you feel you have been denied any of the above opportunities. You cannot in any way be penalized for filing a complaint. Your WIOA sponsor has established a mechanism for handling complaints and grievances.

Your complaint must be filed within 180 days. All complaints will be handled confidentially.

3. Nondiscrimination Laws under WIOA

Title VI of the Civil Rights Act of 1964

Prohibits discrimination on the basis of race, color, national origin, or religion.

The Age Discrimination Act of 1975

Prohibits arbitrary discrimination against persons’ age 40-70.

The Rehabilitation Act of 1973
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Prohibits discrimination based on disability.

Title IX of the Education Amendments of 1972

Prohibits discrimination in any education or training program or activity receiving federal financial assistance.

OTHER CIVIL RIGHTS LAWS:

Title VII of the Civil Rights Acts of 1964

Prohibits discrimination in employment based on race, color, religion, sex, or national origin in all terms and conditions of employment and establishes the Equal Employment Opportunity Commission as the administrative agency.

White House Executive Order no. 11246 as Amended by Executive Order No. 11375

Creates the office of Federal Contract Compliance and prohibits discrimination based on race, color, sex, religion, or national origin.

Department of Labor Secretary’s Order no. 4-73

Prohibits discrimination based on sex.

Equal Pay Act of 1963

Prohibits pay differential solely because of sex.

Emergency Employment Act of 1971

Prohibits discrimination based on race, creed, national origin, political affiliation, or beliefs.

4. How to File Your Complaint

a. Put your complaint in writing.
b. Have it sworn to before a notary public, if possible. c. Provides details that tell what happened, where it happened and when it happened.
d. Give the name and addresses of all persons who were present or who had anything to do with the matter.

...Complaints on the basis of race, color, or national origin, age, sex, religion, political affiliation or belief, retaliation and citizenship, must be filed within 180 days of the alleged occurrence directly with:

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Director
Civil Rights Center
U.S. Department of Labor, Room N-4123
200 Constitution Ave., NW
Washington, D.C. 20210

Complaints on the basis of disability must be filed within 180 days of the alleged occurrence. These complaints must be filed directly with the WIOA administrative entity. The WIOA administrative entity shall issue a written decision within 30 days of the filing of the complaint. If the complaint is still unresolved, an appeal may be made to the Chief of State Workforce Investment Division Office.

The Department of Labor, the Civil Service Commission, the Equal Employment Opportunity Commission, and many other offices and agencies are committed to assuring equal employment opportunities for all persons. They will protect you.

A case may be taken to court if the other processes do not yield satisfactory results.

You may hire your own lawyer, or if you cannot afford one, the court may appoint one for you.

It is unlawful for an employer, union, or employment agency to punish you or any witness for attempting to present the facts in a case.

YOUR CIVIL RIGHTS UNDER THE

WORKFORCE INNOVATION OPPORTUNITY ACT
Santa Ana Local Workforce Development Area
801 W. Civic Center Drive, Suite 200
Santa Ana, CA 92701
(714)565-2600

B. Criminal Complaints

In accordance with the WIOA and the implementing code of Federal section 667.600....

Federal handling of criminal complaints and report fraud, abuse and other criminal activity. “All information and complaints involving fraud, abuse or other criminal activity shall be reported directly and immediately to the City of Santa Ana and the Secretary of Labor.”

II. General Procedures for Handling Non-Criminal Violations of the Act

The following procedure is promulgated to meet the requirements of Title 20, of the Code of Federal Regulations, Section 186 through 188 of the WIOA regulations, and Section 181 of the Act (Public Law 105.200: 29 U.S. Code Sec. 2931 et seq.) at the State and LWDA level for the receipt, investigation, hearing, and resolution of complaints by WIOA participants, sub EXHIBIT 2

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recipients, applicants for participation, or financial assistance, labor unions, community based organizations, or any other persons.

These procedures provide for resolution of non-criminal complaints arising from the operation of the Santa Ana LWDA.

A complaint is defined here as a written expression by a party alleging a violation of the Act, regulations promulgated under the Act, recipient grants, sub agreements, or other specific agreements under the Act, including terms and conditions of employment of such participants in employment training programs. All complaints, amendments and withdrawals shall be in writing. These procedures are intended to resolve matters which concern policies, procedures or action(s) arising in connection with WIOA programs operated by each LWDA grant recipient and sub recipient under the Act.

These procedures shall not be construed as affecting any other available legal remedy outside of the WIOA complaint process (i.e., disputes regarding terms and conditions of employment of any employee who is not a participant), either separately or simultaneously, that a person may wish to pursue in the resolution of a non-WIOA complaint. Also, these procedures do not restrict the LWDA grant recipient staff in carrying out informal discussion

Procedures do not restrict the LWDA grant recipient staff in carrying out informal discussion and resolution of any problems outside of and without resort to the formal complaint procedure.

A. The following principles and rules apply to all complaints at all steps of the complaint procedures:

1. All complaints must be made in writing within 180 days of the alleged occurrence, except complaints alleging fraud or criminal activity.

2. All persons filing a complaint shall be free from restraint, coercion, reprisal, or discrimination. Good faith efforts shall be made to informally resolve the complaint prior to the scheduled hearing. Complainants have the right to withdraw their complaints (in writing) at any time prior to the hearing. A complainant may amend his/her complaint to correct technical deficiencies but not to add issues.

3. Complainants shall have the right to be represented at their own expense by person(s) of their choosing at all levels of the complaint process.

4. Upon enrollment into employment or training, participants shall be provided with a written description of these procedures, including notification of their right to file complaints and instructions for filing.

An employer of participants, including private-for-profit employers of participants, may use this or other complaint resolution procedures so long as the participant is informed of the complaint resolution procedure they are to follow and the time frames governing review of complaints are met.

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A “participant”, within the meaning of these procedures, is an individual who receives employment-training services under a program funded by Santa Ana LWDA. The Complaint Resolution Procedures contained herein (or the alternative procedures which an employer may use) shall be available to participants to resolve disputes regarding items and conditions of employment of such participants in employment training programs. However, such procedures shall not be used to resolve disputes regarding terms and conditions of employment of any employee who is not a participant, as defined herein.

5. If a complaint does not receive a decision at the LWDA grant recipient level within 60 days of filing the complaint or receives an unsatisfactory decision, the complainant then has a right to request a review of the complaint by the Governor.

6. Complainants must initially file and exhaust LWDA grant recipient/hearing procedures prior to appealing to the State except where the State determines that the LWDA grant recipient’s procedures are not in compliance with the State’s procedures.

III. Procedures for Handling Complaints at the LWDA Level

A. Receipt Complaints

Pursuant to the WIOA regulations found at 20 CFR, Section 683.600, the LWDA administrative entities have the responsibility to conduct hearings and resolve complaints made by individuals about the administration of programs in the LWDA. “LWDA level” encompasses LWDA administrative entity and employers to which the administrative entity has delegated the complaint resolution process. The following comprise the guidelines for resolving issues arising in connection with WIOA programs operated by the Santa Ana LWDA including resolutions of complaints arising from actions, such as audit disallowances or the imposition of sanctions taken by the Governor with respect to audit findings, investigations or monitoring reports.

1. Form and Filing of Compliant

Official filing date of the compliant is the date the written complaint is received. The filing of the complaint with the Santa Ana LWDA Equal Employment Opportunity Officer shall be considered as a request for hearing and a decision must be issued within 60 days.

The complaint must be in writing and must be signed and dated. The complaint should also contain the following information:

a. Full name, telephone number, if any, and mailing address of the complainant;

b. Full name, telephone number, and mailing address of the agency involved (respondent);

c. Clear and concise statement of facts including dates constituting alleged violation;

d. What provisions under the Act, regulations, grant or other agreements under the Act, are believed to have been violated;
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e. Remedy sought by the complainant; and

f. If the complainant is a private or public entity or corporation, and not a natural person, the filing of the complaint must be duly authorized by the governing body of such entity or corporation.

The absence of any of the requested information shall not be a basis for dismissing the complaint.

A copy of the complaint must be sent to the respondent and both parties notified of the opportunity for an informal resolution. At each step of the complaint process, the complainant must be notified in writing of the next procedural step.

2. Informal Conference

Informal conferences will be utilized by the Santa Ana LWDA to resolve complaints; however, such informal conferences shall not extend the time within which a decision must be issued after receipt of a complaint. Attempts at informal resolution will commence with two (2) weeks of the date of filing of the complaint.

a. The EEO Officer will review the case and ascertain facts prior to the conference so that appropriate resolution can take place at the time of this meeting whenever possible.

b. Although the complainant should be encouraged to attend this conference, his/her failure to do so should not preclude his/her right to request a hearing on the matter.

c. If mutually satisfactory resolution results and the Santa Ana LWDA concurs, the EEO Officer will write a brief report for the file stating the issues and resolution. The matter shall then be considered closed.

d. If resolution does not result, the complainant shall be provided the necessary information and assistance to request a hearing if he/she so desires.

3. Request for Hearing

a. As in the case of the complaint, the request for a hearing should be put in writing and be filed in person or by mail. A governing board resolution of authorization to appeal should also be submitted when appropriate. The request should be filled with:

Jennifer Sommers
Sr. Personnel Analyst – EEO Officer
20 Civic Center Drive, M-24
Santa Ana, CA 92701
(714) 647-5348

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b. A hearing will be scheduled by the EEO Officer within thirty (30) days of the date of filing of the complaint.

4. Notice of Hearing

Upon receipt of the request for hearing, the complainant and the respondent will be notified in writing of the hearing ten (10) calendar days prior to the date of the hearing.

The ten-day notice may be shortened with the written consent of the parties. A decision will be issued by the Santa Ana LWDA within sixty (60) days of the date of filing of the complaint.

The hearing notice shall be in writing and contain the following information:

a. The date of notice, name of the complainant, and the name of the party against whom the complaint is filed.

b. The date, time and place of hearing before an impartial hearing officer.

c. A statement(s) of the alleged violation(s)

d. Advise as to where information or assistance may be obtained, and the name, address, and telephone number of the Santa Ana LWDA Equal Employment Opportunities (EEO) Officer who can answer inquiries.

B. Conduct of Hearing
The hearing shall be conducted in an informal manner with strict rules of evidence not applicable. Unnecessary technicalities should be avoided. It should provide the flexibility to enable adjustment to the circumstances presented.

1. The hearing officer shall have complete independence to obtain facts and make decisions. The hearing officer shall be in a position to render impartial decisions and thus should not be subordinate to the Santa Ana LWDA or its sub recipients. The hearing officer will be selected from a list of names on file with the EEO Officer.

2. Full regard must be given to the requirements of due process to insure a fair and impartial hearing.

3. The hearing office designated by the EEO Officer to function in a quasi-judicial capacity should begin the hearing by summarizing the record and the issue and should explain the manner in which the hearing will be conducted, making sure that everyone involved understands the proceedings. Such explanations should be adapted to the needs of the specific situation. The hearing officer might take testimony under oath or affirmation to give some assurance of veracity to the hearing.

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4. The burden of proof should be reasonable and flexible, dependent upon the circumstances of the case involved. The hearing officer determines the order of proof.

Generally, the party making the complaint has the obligation of establishing his or her case and should be examined first.

5. The party involved should have the right to be represented (at their own expense) if he/she so desires. Other he/she is limited to his/her own abilities and those to the hearing officer in obtaining testimony in the case.

6. It is important that the hearing officer obtain the fullest information for the record. If the parties involved, or their representatives, do not know how to ask the right or pertinent questions in pursuing their right to due process, it shall be necessary for the hearing officer to step in to have all the materials and relevant facts elicited.

7. The practice in informal hearings is generally not to apply strict rules of evidence in obtaining facts. However, the quantity of evidence required to support a decision on an issue should be sufficiently credible that the state (or other appropriate agency), upon reviewing the decision, would conclude that the decision is supported by substantial evidence.

8. The hearing officer should attempt to negotiate a resolution of the issue at any time prior to the conclusion of the hearing.

9. Within ten (10) days of the conclusion of the hearing, the hearing officer will issue a recommended decision to the LWDA for final determination. The recommended decision shall be in writing and may be accepted, rejected or modified by the Santa Ana Workforce Development Board.

C. Issuance of Decision

Within sixty (60) calendar days of filing of the complaint, the Santa Ana LWDA shall issue a written decision to all parties by first class mail. The final decision shall contain the following information:

1. The name of the parties involved.

2. A statement of the alleged violation and issues related to the alleged violation.

3. A statement of the facts.

4. The decision and the reasons for the decision.

5. A statement of corrective action, if any, to be taken.

6. Notice of the right to request, within ten (10) calendar days of receipt of the decision, a review of the decision by the State Review Panel.

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D. Record of Hearing
An administrative file containing support documents on the complaint resolution process hearing conducted will be retained by the Santa Ana LWDA. The purpose of a record is to serve as substantiation of the process followed by the Santa Ana LWDA on the resolution of the issues and the results. This information would then be available for subsequent review in the event the matter is raised with the State. Such records must be retained for a three- year period after the grant has been officially closed out.

The Santa Ana LWDA’s written decision will be included in the record. Evidence received at the hearing, notes by the hearing officer, stenographer’s notes and tape recordings may also be used.

E. Establishment of Complaint Procedures
In accordance with Section 683.600, each employing agency including private-for-profit employers of participants under the Act is required to establish a complaint procedure for resolving matters relating to the terms and conditions of employment. Employers may operate their own grievance system or may utilize the Santa Ana LWIDA’s established procedures under Section 683.600. At a minimum these procedures must include:

1. Written notice, upon enrollment into employment training services, of the scope and availability of such procedures. Employer’s grievance procedures shall be set forth in a written document and must meet the regulation mandate that a complaint will be resolved with sixty (60) days from the date the complaint was filed. A copy of employer’s grievance procedure shall be provided to each participant upon enrollment in employment training.

2. Written notice, at the time the grievance is filed, of the procedures under which the grievance will be processed.

3. Written notification of the disposition of the grievance and a written decision shall be issued within thirty (30) days of the filing of the grievance unless a present and long established grievance specifically provides other limits; and

4. Written notification of the participant’s right to request a review of the employer’s decision by the Santa Ana LWDA and the State Review Panel in accordance with Section 683.600.

IV. Procedures for Handling Complaints at the State Level

Section 181 (c) of the Act and the WIOA regulations at 20 CFR, Section 683.600 (d) requires the Governor to establish a State Review process of complaints filed at the LWDA grant recipient level and of complaints initially filed at the State level.

Appeals of decisions issued at the LWDA level including audit disallowances and sanctions shall be reviewed by the State Review Panel. The State Review Panel shall review the record EXHIBIT 2

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established at the LWDA level and shall issue a decision based on the information contained therein.

Complaints which may be initially filed at the State level will be heard by an independent hearing officer designated by the State Workforce Investment Division (WID). The hearing officer shall conduct a hearing and issue a recommended decision to the State Panel. The recommended decision shall be in writing and may be accepted, rejected or modified by the State Review Panel.

A. Form and Filing of Complaint.

1. Request for State Review of LWDA Level Decisions

On receipt of a complainant’s request for review because of an unsatisfactory decision, the State shall provide for an independent state review.

2. Filing of Requests for State Review

The State Review Panel shall review all LWDA level decisions when a request for review is filed within 10 days of receipt of the adverse decision. Such requests must be filed in writing with the Chief of the WID Office. The request for review should contain the following information:

a. Full name, address, and telephone number of the party requesting the review b. Full name, address, and telephone number of the other party c. A copy of the decision
d. Brief statement of reasons for review or the section of the LWDA decision to be reviewed including regulatory and statutory citations
e. A statement of the relief sought.

3. Complainant Responsibility

It is the responsibility of the complainant to include in the request for review a written statement setting forth the facts presented at the LWDA hearing which support the requested relief.

The Chief, WID, shall mail a copy of the request for review to the other party and to the LWDA. It shall be the responsibility of the LWDA to submit the complete record including a typed record of the hearing to the Chief, WID, within ten (10) days.

B. Conduct of Hearings.

1. Request for Hearing at the State Level
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If no decision has been issued at the LWDA level or the State has determined an audit disallowance or imposed sanctions, the complainant may request a hearing. The hearing officer will then issue a recommended decision to the State’s Review Panel for final determination.

2. Filing for Request for Review
The request for a State hearing shall be filed within ten (10) days after LWDA should have issued a decision or ten (10) days after the issuance of the audit disallowance or sanction. The request shall be filed directly with the Chief of the WID in writing and should include the following:

a. Full name, address, and telephone number of the LWDA b. Name, address, and telephone number of the LWDA
c. Copies of complaints made at LWDA level from which no decisions were issued or sanctions and imposed.
d. A statement of basis for the request for hearing.

3. Evidentiary Hearing
Upon receipt of the request for a State level hearing, a hearing before a designated hearing officer will be scheduled.

The hearing will be recorded mechanically or by court reporter.

Both parties concerned will have the opportunity to present oral and written testimony under oath, to call and question witnesses in support of his/her position, to present oral and/or written arguments, to examine records and documents relevant to the issue(s), and to be represented.

The hearing officer shall issue a written decision, which shall be forwarded to the State Review Panel for final determination.

The State Review Panel may accept, reject or modify this recommendation. The decision of the State Review Panel is final except for audit disallowances, which must be approved by the Secretary of Labor

C. State Review Panel

The State Review Panel will consist of a panel of three representatives from the Employment Development Department: one from the Legal Offices, one from the WID, and one from the Director’s office. The panel will issue a written decision, which will be sent to the appropriate parties within thirty (30) days of receipt of the request for State review.

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Decisions issued by this panel, under the authority of the Governor, are final.

D. Issuance of State Review Decision.

The State review will be limited to violations of the WIOA, implementing WIOA regulations or the grant agreement. This review shall be limited to the record established at the LWDA hearing.

V. Procedures for Handling Discrimination Complaints by Participants.

A. Complaints on the basis of race, color, or national origin, age, sex, religion, political affiliation or belief, retaliation, and citizenship, where appropriate, must be filed within 180 days of the alleged occurrence.

1. It is the responsibility of the Santa Ana LWDA’s Equal Employment Opportunity (EEO) Officer to determine jurisdiction and to make the complainant aware of and provide assistance in filing a complaint in accordance with the Santa Ana LWDA’s procedure under Section II (A).

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PROCEDURES FOR HANDLING NON-CRIMINAL COMPLAINTS

˚
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Informal Resolution Process
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Unsatisfactory Decision or LWDA Decision not issued within 60 days ˚
˚
˚

˚
˚
˚
If no decision issued by State Review Panel
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˚
Appeal to DOL
60 Days

30 Days
30 Days

No later than
180 days of
alleged
discrimination
Handling of complaints filed at LWDA level arising in connection with WIOA programs operated by LWDAs
Filing of Complaint/Request for Hearing
Notice of Hearing issued by LWDA
Hearing Conducted
LWDA Decision within 60 days
Within 10 days of
receipt of
unsatisfactory
decision or 10
days from date
LWDA decision
should have been
issued.

Request for State Review
Governor’s Decision issued by State Review Panel
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2. In cases where areas of authority overlap, it is the responsibility of the EEO Officer to advise the complainant of the existence of State, Federal and other proper action agencies, which may also have a bearing.

3. Complainants alleging discrimination under this part will be made aware of their right to file directly with the Office of Civil Rights (OCR), U.S. Department of Labor and applicable procedures.

4. Complainants must file their complaint directly with:

Jennifer Sommers
Sr. Personnel Analyst – EEO Officer
20 Civic Center Drive, M-24
Santa Ana, CA 92701
(714) 647-5348

VI. Procedures for Handling Disability Complaints by Participants

Complaints alleging discrimination on the basis of disability will be filed and processed under the Department of Labor regulations implementing Section 504 of the Rehabilitation Act of 1973 at 29 Code of Federal Regulations Section 32.

1. Complaints must exhaust the Santa Ana LWDA’s informal resolution procedures before filing their complaint with OCR.

2. Complainants will be made aware of the 180 days requirement in which to file his/her complaint.

A. Procedures at the LWDA Level

1. The complainant shall file his/her complaint directly with the Santa Ana LWDA. Upon receipt of the complaint, the EEO Officer shall investigate and gather information concerning the complaint.

2. An informal conference will be held with the parties concerned in an effort to resolve the issue(s). The complainant has the right to be present and may be represented during the conference.

3. The Santa Ana LWDA shall issue in writing its decision to the complainant no later than thirty (30) days after the filing of the complaint.

B. Procedures at the State Level

1. The complainant may appeal to the State if he/she is not satisfied with the decision of the Santa Ana LWDA.

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2. The Complainant must file his/her appeal as a request for review directly with the Chief WID within ten (10) calendar days after the receipt of the Santa Ana LWDA’s decision.

3. The Chief-WID, shall issue a decision no later than thirty (30) calendar days after receipt of the request for review.

4. After the complainant has received a decision or no decision has been received from the Director of Employment Development Department (on behalf of the Governor), the complainant has the right to appeal his/her complaint within thirty (30) calendar days to the Office of Civil Rights (OCR) with the Department of Labor.

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PROCEDURES FOR HANDLING COMPLAINTS ON BASES OF DISABILITY

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˚
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If no resolution reached
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Unsatisfactory Decision or No Decision
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˚
˚

˚

No later than
180 days of
alleged
discrimination
Filing of complaint on the basis of Disability with LWDA Filed within 30
days of
LWDA/State
Decision or 90
days from date of
initial filing of
complaints
Informal Resolution

Request for Hearing
Notice of Hearing
Hearing Conducted
LWDA Decision
State Review
Governor’s Decision
Appeal to Assistant Secretary Department of Labor
Day 1
Day /45 Day
60 Days
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GLOSSARY OF WIOA TERM

AGE DISCRIMINATION ACT – A law passed by Congress in 1975 which prohibits discrimination on the basis of age by any program or activity receiving Federal Funds.

APPLICANT – An individual who applies to a subrecipient or contract for services provided under WIOA and who has not yet transitioned to the status of participant.

ASSESSMENT – Services designed to determine each participant’s employability, aptitudes, abilities and interests and to develop a plan to achieve the participant’s employment and related goals; also to identify the available employment and traning activities appropriate for the participant. Testing and counseling may also be used during assessment process.

CHARGING PARTY (CP), COMPLAINANT, GRIEVANT, OR AGGRIEVED PERSON – The person who charges that he/she has been discriminated against under Department of Justice nondiscrimination and civil rights regulations and/or guidelines.

DISCRIMINATION – In general, a failure to treat all equally, whether intentional or unintentional; the effect of an action, policy or practice which selects an individual or class of persons to receive unequal treatment.

ELIGIBLE NON-CITIZEN – Lawfully admitted permanent resident, aliens, lawfully admitted refugees, and parolees and other individuals authorized by the Attorney General to work in the United States.

EMPLOYER – An employer subject to the p rovisions of the Civil Rights Act of 1964, as amended, including state and local governments and any Federal agency subjects to the provisions of Section 717 of the Civil Rights Act, as amended; and any Federal contractor or subcontractor covered by executive Order 11246, as amended.

GRIEVANCE – An allegation that something imposes an illegal obligation or burden or denies some equitable or legal right, or causes injustice .

INDIVIDUAL WITH A DISABILITY – Any individual who has a physical or mental disab ility that constitutes or results in a substantial challenge to employment.

INTAKE – Includes screening to determine eligibility; to select from eligible applicants those individuals who are most in need and can benefit from program services; to complete procedural requirements necessary to enroll an individual into the program and to refer those not enrolled to other programs.

JOINT COMPLAINT – A complaint of employment discrimination covered by Title VII or the Equal Pay Act and by Title VI or Title IX. Individual “joint complaints” are normally investigated by EEOC unless OCR has a compelling reason to investigate. “Joint complaints” alleging discrimination in employment and other practices and pattern or practice “joint complaints” are normally inves tigated by OCR.

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JURISDICTION – Authority to investigate and resolve complaints against an institution subject to a law or statute which has been assigned to OCR for enforcement, i.e., Title VI, Title IX, etc.

PARTICIPANT – Any applicant who has: (1) Been determined eligible for participation upon intake; and (2) Who is receiving subsidized employment, training or services (except post -termination services) funded under the Act, following intake, except for an individual who receives only outreach and/or intake and assessment services.

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ATTACHMENT I - BUDGET NARRATIVE

WORKING WARDROBES FOR A NEW START

REBUILDING CAREERS FOR YOUNG ADULTS

BUDGET NARRATIVE

PERSONNEL SALARIES

1. Client Services Manager (.20 FTE): $15,750
Dedicate 21% of time to program over 12 months. Provide program management, oversee participant services, ensure compliance with program requirements, complete data reporting, and coordinate with community partners and support services.

2. Career Navigator (1 FTE): $56,160
Dedicate 100% of time to the program over 12 months. Provide case management and career navigation services, assist with participant intake, enrollment, referrals, job placement, and facilitate educational and vocational training opportunities.

3. Client Services Coordinator (.15 FTE): $6,177.60
Dedicate 15% of time to program over 12 months. Assist in screening referrals, tracking participant data, scheduling client appointments, and providing administrative support to the Client Services Manager and Career Navigator.

4. Retail Manager/WEX Supervisor (.20 FTE): $10,816
Dedicate 20% of time to program over 12 months. Provides day-to-day supervision and training to the WEX participants within Social Enterprise; assigns tasks that support skill development and exposure to workplace expectations; verifies participant attendance and approves timesheets; communicates performance, attendance, or workplace concerns to Working Wardrobes staff.

TOTAL PERSONNEL SALARIES = $88,853.60

PERSONNEL BENEFITS

1. Client Services Manager (0.20 FTE): $3140.00 Benefits calculated based on 20% of 20% FTE salary, covering Social Security, Medicare, unemployment insurance (SUI), health insurance, and workers' compensation.

2. Career Navigator (1.0 FTE): $15,724.80 Benefits calculated based on 28% of 100% FTE salary, covering Social Security, Medicare, unemployment insurance (SUI), health insurance, and workers' compensation.

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3. Client Services Coordinator (0.15 FTE): $1,235.52 Benefits calculated based on 20% of 15% FTE salary, covering Social Security, Medicare, unemployment insurance (SUI), health insurance, and workers' compensation.

4. Retail Manager/WEX Supervisor (0.20 FTE): $3,028.48 Benefits calculated based on 28% of 15% FTE salary, covering Social Security, Medicare, unemployment insurance (SUI), health insurance, and workers' compensation.

TOTAL PERSONNEL BENEFITS = $23,128.80
TOTAL PERSONAL SALARIES AND BENEFITS = $111,982.40

OPERATING EXPENSES

OFFICE EXPENSES
Casebook CRM system subscription to manage program and client data (25% of total annual expense allocated to this program) = $2,500
Total Office Expenses = $2,500

INDIRECT COST
Per Working Wardrobes for a New Start’s Negotiated Indirect Cost Rate Agreement with the U.S. Department of Labor for the program period. The total staff cost of $111,982.40, staff mileage of $481 and office expenses of $2,500, when multiplied by 0.2172, equals $24,970.05.

Total Indirect Cost = $24,970.05
Staff Travel/Mileage
Mileage reimbursement for staff travel to and from correctional facilities and partner agencies is calculated based on an estimated 664 miles to be traveled at a rate of $0.725 per mile.

Total Staff Travel/Mileage = $481

PARTICIPANT WAGES (WAGE + TAX)
Participant wages include the payment of wages ($18/hr) for participants completing work experience (WEX) as part of the program (120 hours x 10 participants). These wages cover both the base wage and associated taxes (13%). Participants will be placed at Working EXHIBIT 2

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Wardrobe locations including, Career Success Center, The Hanger retail stores and Donation Center.
● $18/hour x 120 hours + 13% (tax rate) = $24,408 total for 10 participants Total Cost for 10 Participant Wages = $24,408 (including taxes)

PARTICIPANT TUITION ASSISTANCE
An average of $750 for 20 participants equally $1,5000 will be made available for tuition assistance and training related expenses for participants pursuing skill-based training certificate programs and/or post-secondary education. These funds are essential fo5r allowing participants to further their education and gain skills that will help them succeed in the workforce.

Total Participant Tuition Assistance = $15,000

SUPPORTIVE SERVICES
Supportive services are designed to assist participants with their critical needs, removing barriers to employment, and ensuring they can successfully complete the program.

Supportive services may include: Financial assistance for transportation, government IDs, utilities, or other necessary resources. Any supportive services payment will be provided in the form of a gift card or directly paid to the appropriate third party vendor.

Total Supportive Services ($250 x 20 Participants) = $5,000

Participant Incentives
Participants may receive incentives valued at up to $125 upon achievement of verified initial employment. Incentives may be provided in the form of gas cards, grocery cards (such as Walmart or similar retailers), or general prepaid Visa gift cards. This incentive is intended to recognize progress and encourage continued engagement in services that support employment outcomes. All incentives are issued only after staff verify completion and document the achievement in accordance with program procedures.

Total Participant Incentives ($125 x 14 Participants) = $1,750 Follow Up Period, Supportive Services
Supportive services during the follow-up period are designed to assist participants with their critical needs, removing barriers to employment retention, and ensuring they can successfully maintain employment after program completion. Supportive services may EXHIBIT 2

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include financial assistance for transportation, government IDs, utilities, or other necessary resources. Any supportive services payment will be provided in the form of a gift card or directly paid to the appropriate third-party vendor.

Total Follow Up Period ($100.61 x 14 Participants) = $1,408.55 Follow Up Period, Incentives
Participants may receive incentives valued at up to $125 upon achievement of verified 2nd quarter and 4th quarter post-exit employment, with one incentive issued per qualifying quarter. Incentives may be provided in the form of gas cards, grocery cards (such as Walmart or similar retailers), or general prepaid Visa gift cards. These incentives are intended to recognize progress and encourage continued engagement in services that support employment outcomes. All incentives are issued only after staff verify completion and document the achievement in accordance with program procedures.

Total Follow Up period, Participant Incentives ($125 x 14 Participants) = $3,500

PARTICIPANT PROFESSIONAL SERVICES
This category covers the costs of professional services, such as career readiness workshops and professional wardrobe assistance, provided to participants to ensure they are equipped for navigating the job market. Wardrobe services provide each participant with the necessary interview attire, one ‘business casual’ outfit (including top, bottom, accessories and shoes) for interviews and on-the-job use. For 20 participants, the cost for wardrobe services is $150 per outfit, totaling $3,000.00.

Additionally, the program includes workforce and life skills workshops for participants.

These workshops focus on topics such as self-assessment strategies, resume building, job search skills, interview techniques, navigating workplace success, and financial literacy. 10 workshops will be provided throughout the year at $600 per workshop. Each includes all materials, interactive activities and led by a trained Facilitator.

The total cost for the 10 workshops is $6,000.00
Total Participant Professional Services (Workshops/Wardrobing) = $9,000.00 TOTAL OPERATING EXPENSES: $174,778.61
INDIRECT COSTS (21.72% per NICRA with U.S. Dept. of Labor): $25,221.40 TOTAL BUDGET: $200,000
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ATTACHMENT I - BUDGET NARRATIVE

WEX Related Expenses Breakdown
In compliance with WIOA Youth Work Experience Program requirements that a minimum of 25% of local area funds are spent on work experience, the following expenses will be dedicated to the WEX program.

Personnel – Program staff will focus a percentage of their time developing WEX opportunities, preparing and interviewing clients for roles, onboarding, training and supervising participants during the work experience. This includes:
• Career Navigator-approximately 25% of their time: $17,971 ($71,884 x .25) • Retail Manager/WEX Supervisor 100% of their time: $13,956 • Client Services Manager- approximately 15% of their time: $2,826 ($18,840 x .15) Participant Wages - 10 WEX participants will be paid $18/hr for 120hrs • Participant Wages: $24,408
Total WEX-related expenses = $59,161 which is 29.6% of total expenses.

ADDITIONAL BUDGET INFORMATION
Program staff will document and track schedule, timecards, and payments of WEX Participant wages to verify eligibility, ensure that individual participants do not exceed the maximum wage payment, and that the total line item budget is not exceeded. If participants are gaining paid work experience off-site with a partner, the partner will report hours to Working Wardrobes. All WEX participants will be categorized as part-time, temporary employees of Working Wardrobes during their participation in the WEX program only. Payments will be made directly to participants in the form of company checks or direct deposit, and no cash will be distributed.

Tracking and Documentation
All Participant Supportive Services payments for critical needs addressing barriers to employment, and Participant Skills Development tuition and training-related expenses, will be carefully controlled by program staff to maintain fiscal integrity and adherence to the program budget. Gasoline and public transportation assistance will be provided to clients in the form of gas company debit cards or bus line pass cards, which will be distributed to participants once eligibility and need are confirmed by a Career Navigator.

The need and value of other Supportive Services and Skills Development (Training) expenses will be documented through bills, invoices, receipts, quotes, or other supporting EXHIBIT 2

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documents secured by program staff or participants and confirmed with the appropriate vendor prior to payment. All payment requests will be initiated by the program’s Career Navigator, reviewed and approved by the Client Services Manager and/or Director of Client Services before disbursements are issued.

Subcontracting
Working Wardrobes attests that no duties or work related to this program will be subcontracted or assigned to any other organization, consultant, or person without the prior written consent of the City.

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Budget Form
Administrative
Cost (Not to
Exceed 10%)
Total Program
Cost
Total WIA Cost
1 Client Services Manager - 78500/yr @ 0.20 fte $15,700.00 $15,700.00 2 Career Navigator - $27 per hour @ 56,160 /yr
@1.00 FTE $56,160.00 $56,160.00
3 Client Services Coordinator $6,177.60 $6,177.60
4 Retail Manager/WEX Supervisor $10,816.00 $10,816.00
5 1 Client Services Manager $3,140.00 $3,140.00
2 Career Navigator $15,724.80 $15,724.80
3 Client Services Coordinator $1,235.52 $1,235.52
4 Retail Manager/WEX Supervisor $3,028.48 $3,028.48
5 Total Personnel Salaries & Benefits $111,982.40 $111,982.40 Rent
Utilities
Phones
Internet Fees
Parking Fees
Security
Maintenance
Insurance
Equipment rental fees*
Equipment rental fees*
Vehicle lease*
Office expenses (consumables) $2,500.00 $2,500.00
Accounting Services
Legal Services
Auditing Services
Indirect Cost* $24,970.05 $24,970.05
Staff Training
Staff Conferences
Staff Travel/Mileage $481.00 $481.00
Participant Wages* $24,408.00 $24,408.00
Paid Tuition Assistance $15,000.00 $15,000.00
Supportive Services* $5,000.00 $5,000.00
Participant Incentives* $1,750.00 $1,750.00
Follow Up Period, Supportive Services* $1,408.55 $1,408.55 Personnel Benefits
Personnel Salaries
Operating Expenses

EXHIBIT D
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Budget Form
Follow Up Period, Participant Incentives* $3,500.00 $3,500.00 Youth Conferences
Participant Professional Services
(workshops/wardrobing) 10 x 600 wrkshp 20 x 150
ward $9,000.00 $9,000.00
Total Operating Expenses $24,970.05 $63,047.55 $88,017.60 GRAND TOTAL (Personnel + Operating) $24,970.05 $175,029.95 $200,000.00

Personnel

OPERATING EXPENSES
Participant Incentives: Indicate the type of payment, rate of payment and describe what youth must achieve to receive the incentive.

Other: This item may include fieldtrips and youth stipends. All items must listed and include cost details.

Equipment Rental Fee (equipment may not be purchased): List items that will be used for this project.

Provide percent of rental fee that will be charged to this project. Describe how percentage was Vehicle Lease (vehicles may not be purchased): Provide list of vehicles dedicated for this project. Describe vehicle use and percentage of use that will be charged to this project. Describe how percentage was Indirect Cost: Provide indirect cost rate plan.

Participant Wages: Describe costs directly related to individual participants such as paid training and/or work experience. Include number of youth, hourly wage, benefits and bonuses. Include length of activity.

Support Services: Attach policies and procedures for supportive services. Policy must include spending limits.

Benefits: List each individual position dedicated to this project. List title, percentage of full time equivalent (FTE) or the amount of time to be charged to this project.

Rent or User Fee: Provide percent of office space that will be charged to this project. Describe how percentage was determined.

All costs related to the program activities described in the proposal must be included on the Budget Form. A budget narrative must be attached on a separate sheet of paper for all line items marked with an * asterisk.

Budget Form Instructions for YSPN Membership
Salaries: List each individual position dedicated to this project. List title, percentage of full time equivalent (FTE) or the amount of time to be charged to this project.

EXHIBIT D
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Budget Form
States, local governments and non-profit institutions who receive $500,000 or more in federal funds in a fiscal year shall meet the audit requirements of the OMB Circular A-133, “Audits of States, and Local

EXHIBIT D
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CITY OF SANTA ANA

ATTACHMENT E

NON-LOBBYING CERTIFICATION
he prospective participant certifies, by signing and submitting this bid or proposal, to the best of his or her knowledge and belief, that:
(1) No Federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, to any person for influencing or attempting to influence an officer or employee of any Federal agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement.
(2) If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any Federal agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this Federal contract, grant, loan, or cooperative agreement, the undersigned shall complete and submit Standard Form-LLL, "Disclosure of Lobbying Activities," in conformance with its instructions.

This certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into. Submission of this certification is a prerequisite for making or entering into this transaction imposed by Section 1352, Title 31, U.S. Code. Any person who fails to file the required certification shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such failure.

The prospective participant also agrees by submitting his or her bid or proposal that he or she shall require that the language of this certification be included in all lower tier subcontracts, which exceed $100,000 and that all such subrecipients shall certify and disclose accordingly.

Signed: �
;;
Title:

Firm:

Date:

Chief Executive Officer
Working Wardrobes for a New Start
THIS FORM MUST BE COMPLETED AND INCLUDED WITH THE PROPOSAL.

PROPOSALS THAT DO NOT CONTAIN THIS FORM WILL BE CONSIDERED NON RESPONSIVE.

City of Santa Ana RFP No, 25-019A Page 69 of 101
3/26/26
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DIVISION OF EMPLOYMENT SERVICES

PLACE OF PERFORMANCE

FOR CERTIFICATION REGARDING DRUG-FREE WORKPLACE
REQU !REM ENTS
Name: Bonni Pomush, Chief Executive Officer
Name of Contractor: Working Wardrobes for a New S tart
Contractor Number: �A�-2=0=2=5_- ______ _
Date: July 1, 2026 - June 30, 2027
The Contractor shall insert in the space provided below the site(s) expected to be used for the performance of work under the contract covered by the certification:

Place of Performance (include street address, city, county, state, zip code for each site):
2000E. McFadden Ave., Santa Ana, CA 92705
Address

EXHIBIT F
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Certification Regarding Drug-Free Workplace Requirements The certification set out below is a material representation upon which reliance is placed by the U.S. Department of Housing and Urban Development in awarding the grant. If it is later determined that the contractor knowingly rendered a false certification, or otherwise violates the requirements of the Drug-Free Workplace Act, the U.S. Department of Housing and Urban Development, in addition to any other remedies available to the Federal Government, may take action authorized under the Drug-Free Workplace Act.

CERTIFICATION
A. The contractor certifies that it will provide a drug-free workplace by:
(a) Publishing a statement notifying employees that the unlawful manufacture, distribution, dispensing, possession or use of a controlled substance is prohibited in the contractor's workplace and specifying the actions that will be taken against employees for violation of such prohibition;
(b) Establishing a drug-free awareness program to inform employees about
(1) The dangers of drug abuse in the workplace;
(2) The contractor's policy of maintaining a drug-free workplace; (3) Any available drug counseling, rehabilitation, and employee assistance program; and
(4) The penalties that may be imposed upon employees for drug abuse violations occurring in the workplace;
(c) Making it a requirement that each employee who will be engaged in the performance of the grant be given a copy of the statement required by paragraph (a);
(d) Notifying the employee in the statement required by paragraph -(a) that, as a condition of employment under the contract, the employee will
(1) Abide by the terms of the statement; and
(2) Notify the employer of any criminal drug statute conviction for a violation occurring in the workplace no later than five days after such conviction.

EXHIBIT F
EXHIBIT 2

City Council
15 –
199
6/16/2026

(e) Notifying the U.S. Department of Housing and Urban Development within ten days after receiving notice under subparagraph (d)(2) from an employee or otherwise receiving actual notice of such conviction; (f) Taking one of the following actions, within 30 days of receiving notice under subparagraph (d)(2), with respect to any employee who is so convicted
(1) Taking appropriate personnel action against such an employee, up to and including termination; or
(2) Requiring such employee to participate satisfactorily in a drug abuse assistance or rehabilitation program approved for such purposes by a Federal, State, or local health, law enforcement, or other appropriate agency;
(g) Making a good faith effort to continue to maintain a drug-free workplace through implementation of paragraphs (a), (b), (c), (d), (e) and (f).

B. The contractor shall insert in the space provided on the attached "Place of Performance" form the site(s) for the performance of work to be carried out with the grant funds (including street address, city, county, state, and zip code). The contractor further certifies that, if it is subsequently determined that additional sites will be used for the performance of work under the contract, it shall notify the U.S. Department of Housing and Urban Development immediately upon the decision to use such additional sites by submitting a revised "Place of Performance" form.

Date

EXHIBIT F
3/26/26
EXHIBIT 2

City Council
15 –
200
6/16/2026

INSTRUCTION FOR CERTIFICATION

1. By signing and submitting this proposal, the prospective recipient of Federal assistance funds is providing the certification as set out below.

2. The certification in this clause is a material representation of fact upon which reliance was placed when this transaction was entered into. If it is later determined that the prospective recipient of Federal assistance funds knowingly rendered an erroneous certification, in addition to other remedies available to the Federal Government, the Department of Labor (DOL) may pursue available remedies, including suspension and/or debarment.

3. The prospective recipient of Federal assistance funds shall provide immediate written notice to the person to which this proposal is submitted if at any time the prospective recipient of Federal assistance funds learns that its certification was erroneous whom submitted or has become erroneous by reason of changed circumstances.

4. The terms "covered transaction", "debarred", "suspended", "ineligible", "lower tier covered transaction11
,
11 participant", "person11
, (/primary covered transaction 1
', "principal", "proposal", and
"voluntarily excluded", as used in this cause, have the meanings set out in the Definitions and Coverage sections of rules implementing Executive Order 12549. You may contact the person to whom this proposal is submitted for assistance in obtaining a copy of those regulations.

5. The prospective recipient of Federal assistance funds agrees by submitting this proposal that, should the proposed covered transaction be entered into, it shall not knowingly enter into any lower tier covered transaction with a person who is debarred, suspended, declared ineligible, or voluntarily excluded from participation in this covered transaction, unless authorized by the DOL.

6. The prospective recipient of Federal assistance funds agrees by submitting this proposal, that it will include the clause title "Certification Regarding Debarment, Suspension, Ineligible, and Voluntary Exclusion" from the covered transaction unless it knows that the certification is erroneous.

7. Nothing contained in the foregoing shall be construed to require establishment of a system of records in order to render in good faith the certification required to exceed that which is normally possessed by a prudent person in the ordinary course of business dealings.

8. Except for transactions authorized under paragraph 5 of these instructions, if a participant in a covered transaction knowingly enters into a lower tier covered transaction with a person who is suspended, debarred, ineligible, or voluntary excluded from participation in this transaction, in addition to other remedies available to the Federal Government, the DOL may pursue available remedies, including suspension and/or debarment.

EXHIBITG
EXHIBIT 2

City Council
15 –
201
6/16/2026

Certification Regarding
Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions
This certification is required by the regulations implementing Executive Order 12549, as amended Non procurement, Debarment and Suspension, 2 CFR Part 2998, Subpart C, Responsibilities of Participants Regarding Transactions. The regulations were published as Part VII of the May 26, 1988, Federal Register, Vol. 53, No. 102 (Pages 19160-19211), and subsequently amended in 81 Federal Register 25585.
(Before completing certification, read instructions which are an integral part of certification)

1. The prospective primary participant, (i.e. grantee) certifies to the best of its knowledge and belief, that it and its principals:
a. Are not presently excluded or disqualified;
b. Have not been convicted within the preceding three years of any of the offenses listed in 2 CFR 180.800(a) convicted or had a civil judgment rendered against them for one of those offenses within that time period.
c. Are not presently indicted for or otherwise criminally or civilly charged by a government entity (Federal, State or local) with commission of any of the offenses listed in 2 CFR 180.800(a); and
d. Have not had one or more public transactions (Federal, State or local) terminated within the preceding three years for cause or default.

2. Where the prospective primary participant is unable to certify to any of the statements in this certification, such prospective participant shall attach an explanation to this proposal.

Working Wardrobes for a New Start
Grantee/Contractor Organization
Bonni Pomush, Chief Executive Officer�
Name and Title of Official Authorized to Certify
On Behalf of the Grantee
Date

EXHIBITG
3/26/26
EXHIBIT 2

City Council
15 –
202
6/16/2026

Assurances & Certifications
Selected providers will be required to sign and submit "actual" assurances and certificates as required by the City of Santa Ana and the Workforce Development Board on all contracts.

I recognize that I must give assurances for each item below. Ifl cannot, this proposal will be automatically rejected. Please initial each box.
fil!I I am authorized by my Board of Directors, Trustees, other legally qualified officer, or as the owner of this agency or business to submit this proposal.
i We are not currently on any Federal, State of California, or local Debarment list.

We will provide records to show that we are fiscally solvent, if needed.

We have, or will have, all of the fiscal control and accounting procedures needed to ensure that WIOA funds will be used as required by law and contract. {liJ We have additional funding sources and will not be dependent on WIOA funds alone.

We do or will meet the applicable Federal, State, and local compliance requirements. These include, but are not limited to:

Records accurately reflect actual performance.

Maintain record confidentiality, as required.
' Reporting financial, participant, and performance data, as required.

Comply with State and Federal fiscal and program activity audits.

Complying with Federal and State non-discrimination provisions.

Meeting requirements of Section 504 of the Rehabilitation Act of 1973.

Meeting requirements of the American's with Disabilities Act of 1990. (submit completed survey) Meeting all applicable labor law, including Child Labor Law standards.

Agree to provide a drug free workplace.

Agree to insure the City of Santa Ana through General Liability Insurance and Automobile Liability Coverage in the amount of$1,000,000.00 policy.
£Z!I Agree to provide all participants with Grievance Procedures. [ii'! Agree to insure proposer's employees through Workers Compensation Insurance (including part-time employees)
� Procurement policies and procedures are in place and meet federal guidelines.

We will not:

I
Place a youth in a position that will displace a current employee.

Use WIOA money to assist, promote, or deter union organizing.

Use funds to employ or train of persons in sectarian activities.

Use funds for youth in the construction, operation, or maintenance of any part of a facility to be used for sectarian instruction or religious worship.
r/!f Use WIOA funds for activities that would interfere with or replace regular academic requirements for eligible youth who are not dropouts.
l{'b'I Use WIOA funds to carry out programs funded under the School-to-Work Opportunities Act of 1994 ,M. unless the program(s) are only for youth eligible to participate under WIOA. 11,..'1 Use WIOA money under this contract to purchase any equipment.

I hereby assm·e that all of the above are true.

Chief Executive Officer
Title

EXHIBITH
3/26/26
Date
EXHIBIT 2

City Council
15 –
203
6/16/2026

09/18/2025
Poms & Associates Insurance Brokers
CA License #0814733
4500 Park Granada, Suite 206
Calabasas CA 91302
Marci Davis
(800) 578-8802 (818) 449-9321
[email protected]
Working Wardrobes For A New Start
2000 E. McFadden Ave
Suite 100
Santa Ana CA 92705
Nonprofits Ins. Alliance of CA (NIAC) 160
25-26 MASTER
A Y Y 2024-49231 09/17/2025 09/17/2026
1,000,000
500,000
20,000
1,000,000
2,000,000
2,000,000
Liquor Liability - Common
Cause
1,000,000
A Y Y 2024-49231 09/17/2025 09/17/2026
1,000,000
Uninsured Motorist
Stacked
1,000,000
A 2024-49231-UMB 09/17/2025 09/17/2026
2,000,000
3,000,000
A
Improper Sexual Conduct & Physical
Abuse 2024-49231 09/17/2025 09/17/2026
General Aggregate $2,000,000
Each Claim $1,000,000
The City of Santa Ana, its officers, officials, employees, and volunteers are to be covered as additional insureds on the CGL policy with respect to liability arising out of work or operations performed by or on behalf of the Contractor including materials, parts, or equipment furnished in connection with such work or operations. Such insurance as is afforded by this policy shall be primary, and any insurance carried by City shall be excess and noncontributory. Waiver of Subrogation applies per the attached forms.
30 day notice of cancellation (except for 10 day notice of cancellation for non-payment) City of Santa Ana ATTN: Audrey Goodson
801 W. Civic Center Dr.

Suite 200
Santa Ana CA 92701

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.

INSURER(S) AFFORDING COVERAGE
INSURER F :

INSURER E :

INSURER D :

INSURER C :

INSURER B :

INSURER A :

NAIC #
NAME:

CONTACT
(A/C, No):

FAX
E-MAIL
ADDRESS:

PRODUCER
(A/C, No, Ext):

PHONE

INSURED
REVISION NUMBER:CERTIFICATE NUMBER:COVERAGES
IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

OTHER:
(Per accident)
(Ea accident)
$
$
N / A
SUBR
WVD
ADDL
INSD

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS

CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. $
$
$
$PROPERTY DAMAGE
BODILY INJURY (Per accident)
BODILY INJURY (Per person)

COMBINED SINGLE LIMIT

AUTOS ONLY

AUTOSAUTOS ONLY

NON-OWNED

SCHEDULEDOWNED

ANY AUTO

AUTOMOBILE LIABILITY
Y / N

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY
OFFICER/MEMBER EXCLUDED?
(Mandatory in NH)
DESCRIPTION OF OPERATIONS below
If yes, describe under

ANY PROPRIETOR/PARTNER/EXECUTIVE
$
$
$
E.L. DISEASE - POLICY LIMIT
E.L. DISEASE - EA EMPLOYEE
E.L. EACH ACCIDENT
ER
OTH-

STATUTE
PER

LIMITS(MM/DD/YYYY)

POLICY EXP
(MM/DD/YYYY)

POLICY EFF

POLICY NUMBERTYPE OF INSURANCELTR
INSR
DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

EXCESS LIAB
UMBRELLA LIAB $EACH OCCURRENCE
$AGGREGATE
$
OCCUR

CLAIMS-MADE
DED RETENTION $
$PRODUCTS - COMP/OP AGG
$GENERAL AGGREGATE
$PERSONAL & ADV INJURY
$MED EXP (Any one person)
$EACH OCCURRENCE

DAMAGE TO RENTED
$PREMISES (Ea occurrence)

COMMERCIAL GENERAL LIABILITY

CLAIMS-MADE OCCUR
GEN'L AGGREGATE LIMIT APPLIES PER:

POLICY PRO-

JECT LOC

CERTIFICATE OF LIABILITY INSURANCE

DATE (MM/DD/YYYY)

CANCELLATION

AUTHORIZED REPRESENTATIVE
ACORD 25 (2016/03)
© 1988-2015 ACORD CORPORATION. All rights reserved.

CERTIFICATE HOLDER
The ACORD name and logo are registered marks of ACORD
HIRED

AUTOS ONLY
EXHIBIT 2

City Council
15 –
204
6/16/2026

Working Wardrobes For A New Start
00017425
Poms & Associates Insurance Brokers
25 Certificate of Liability Insurance
*This certificate supersedes all previously issued certificates.

ACORD 101 (2008/01)
The ACORD name and logo are registered marks of ACORD
© 2008 ACORD CORPORATION. All rights reserved.

THIS ADDITIONAL REMARKS FORM IS A SCHEDULE TO ACORD FORM, FORM NUMBER: FORM TITLE:

ADDITIONAL REMARKS
ADDITIONAL REMARKS SCHEDULE Page of
AGENCY CUSTOMER ID:

LOC #:

AGENCY

CARRIER NAIC CODE

POLICY NUMBER

NAMED INSURED
EFFECTIVE DATE:

EXHIBIT 2

City Council
15 –
205
6/16/2026

1-□1 NONPROFITS

INSURANCE
POLICY NUMBER: 2024-49231 FORM: NIAC-E26 11 17
- ALLIANCE OF CALIFORNIA
NAMED INSURED: Working Wardrobes for A New Start dba: Working Wardrobes
A Head for Insurance. A Heart for Nonprofits.

THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY.

WAIVER OF TRANSFER OF RIGHTS OF RECOVERY

AGAINST OTHERS (WAIVER OF SUBROGATION)
This endorsement modifies insurance provided under the following:

COMMERCIAL GENERAL LIABILITY COVERAGE PART

SOCIAL SERVICE PROFESSIONAL LIABILITY COVERAGE FORM

SCHEDULE
Name of Person or Organization:

Where you are so required in a written contract or agreement currently in effect or becoming effective during the term of this policy, we waive any right of recovery we may have against that person or organization, who may be named in the schedule above, because of payments we make for injury or damage.

NIAC-E26 11 17 Page 1 of 1
EXHIBIT 2

City Council
15 –
206
6/16/2026

1-□1 NONPROFITS

INSURANCE
- ALLIANCE OF CALIFORNIA
A Head for Insurance. A Heart for Nonprofits. POLICY NUMBER: 2024-49231 THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY.

ADDITIONAL INSURED

PRIMARY AND NON-CONTRIBUTORY

ENDORSEMENT FOR PUBLIC ENTITIES
This endorsement modifies insurance provided under the following:

COMMERCIAL GENERAL LIABILITY COVERAGE PART

SCHEDULE
Name of Person or Organization:

City Of Santa Ana, officers, agents, employees and volunteers A. Section II - WHO IS AN INSURED is amended to include:

4. Any public entity as an additional insured, and the officers, officials, employees, agents and/or volunteers of that public entity, as applicable, who may be named in the Schedule above, when you have agreed in a written contract or written agreement presently in effect or becoming effective during the term of this policy, that such public entity and/or its officers, officials, employees, agents and/or volunteers be added as an additional insured(s) on your policy, but only with respect to liability for "bodily injury'', "property damage" or "personal and advertising injury'' caused, in whole or in part, by:
a. Your negligent acts or omissions; or
b. The negligent acts or omissions of those acting on your behalf; in the performance of your ongoing operations.

No such public entity or individual is an additional insured for liability arising out of the sole negligence by that public entity or its designated individuals. The additional insured status will not be afforded with respect to liability arising out of or related to your activities as a real estate manager for that person or organization.

B. Section Ill - LIMITS OF INSURANCE is amended to include:

8. The limits of insurance applicable to the public entity and applicable individuals identified as an additional insured(s) pursuant to Provision A.4. above, are those specified in the written contract between you and that public entity, or the limits available under this policy, whichever are less. These limits are part of and not in addition to the limits of insurance under this policy.

C. With respect to the insurance provided to the additional insured(s), Condition 4. Other Insurance of SECTION IV - COMMERCIAL GENERAL LIABILITY CONDITIONS is replaced by the following:

4. Other Insurance
a. Primary Insurance
This insurance is primary if you have agreed in a written contract or written agreement:
(1) That this insurance be primary. If other insurance is also primary, we will share with all that other insurance as described in c. below; or
NIAC-E61 02 19 Page 1 of 2
EXHIBIT 2

City Council
15 –
207
6/16/2026

1-□1 NONPROFITS

INSURANCE
- ALLIANCE OF CALIFORNIA
A Head for Insurance. A Heart for Nonprofits. POLICY NUMBER: 2024-49231 (2) The coverage afforded by this insurance is primary and non-contributory with the additional insured(s)' own insurance.

Paragraphs (1) and (2) do not apply to other insurance to which the additional insured(s) has been added as an additional insured or to other insurance described in paragraph b. below. b. Excesslnsurance
This insurance is excess over:

1. Any of the other insurance, whether primary, excess, contingent or on any other basis:
(a) That is Fire, Extended Coverage, Builder's Risk, Installation Risk or similar coverage for "your work";
(b) That is fire, lightning, or explosion insurance for premises rented to you or temporarily occupied by you with permission of the owner;
(c) That is insurance purchased by you to cover your liability as a tenant for "property damage" to premises temporarily occupied by you with permission of the owner; or (d) If the loss arises out of the maintenance or use of aircraft, "autos" or watercraft to the extent not subject to Exclusion g. of SECTION I - COVERAGE A- BODILY INJURY AND PROPERTY DAMAGE.
(e) Any other insurance available to an additional insured(s) under this Endorsement covering liability for damages which are subject to this endorsement and for which the additional insured(s) has been added as an additional insured by that other insurance. (1) When this insurance is excess, we will have no duty under Coverages A or B to defend the additional insured(s) against any "suit" if any other insurer has a duty to defend the additional insured(s) against that "suit". If no other insurer defends, we will undertake to do so, but we will be entitled to the additional insured(s)' rights against all those other insurers. (2) When this insurance is excess over other insurance, we will pay only our share of the amount of the loss, if any, that exceeds the sum of:
(a) The total amount that all such other insurance would pay for the loss in the absence of this insurance; and
(b) The total of all deductible and self-insured amounts under all that other insurance. (3) We will share the remaining loss, if any, with any other insurance that is not described in this Excess Insurance provision and was not bought specifically to apply in excess of the Limits of Insurance shown in the Declarations of this Coverage Part. c. Methods of Sharing
If all of the other insurance available to the additional insured(s) permits contribution by equal shares, we will follow this method also. Under this approach each insurer contributes equal amounts until it has paid its applicable limit of insurance or none of the loss remains, whichever comes first.

If any other the other insurance available to the additional insured(s) does not permit contribution by equal shares, we will contribute by limits. Under this method, each insurer's share is based on the ratio of its applicable limit of insurance to the total applicable limits of insurance of all insurers.

NIAC-E61 02 19 Page 2 of 2
EXHIBIT 2

City Council
15 –
208
6/16/2026

POLICY NUMBER: 2024-49231 COMMERCIAL AUTO
CA 04 44 10 13
THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY.

CA 04 44 10 13 © Insurance Services Office, Inc., 2011 Page 1 of 1

WAIVER OF TRANSFER OF RIGHTS OF RECOVERY

AGAINST OTHERS TO US (WAIVER OF SUBROGATION)
This endorsement modifies insurance provided under the following:

AUTO DEALERS COVERAGE FORM

BUSINESS AUTO COVERAGE FORM

MOTOR CARRIER COVERAGE FORM
With respect to coverage provided by this endorsement, the provisions of the Coverage Form apply unless modified by the endorsement.

This endorsement changes the policy effective on the inception date of the policy unless another date is indicated below.

Named Insured:

Endorsement Effective Date:

SCHEDULE
Name(s) Of Person(s) Or Organization(s):

Any person or organization with whom you have a written contract currently in effect or becoming effective during the term of this policy.

Information required to complete this Schedule, if not shown above, will be shown in the Declarations.

The Transfer Of Rights Of Recovery Against
Others To Us condition does not apply to the
person(s) or organization(s) shown in the Schedule,
but only to the extent that subrogation is waived prior to the "accident" or the "loss" under a contract with
that person or organization.

EXHIBIT 2

City Council
15 –
209
6/16/2026

POLICY NUMBER: 2024-49231
Named Insured: Working Wardrobes for A New Start dba: Working War

COMMERCIAL GENERAL LIABILITY
CG 20 10 12 19
THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY.

ADDITIONAL INSURED - OWNERS, LESSEES OR

CONTRACTORS - SCHEDULED PERSON OR

ORGANIZATION
This endorsement modifies insurance provided under the following:

COMMERCIAL GENERAL LIABILITY COVERAGE PART

SCHEDULE
Name Of Additional Insured Person(s}
Or Organization(s} Location(s} Of Covered Operations
Any person or organization that you are required to All insured premises and operations. add as an additional insured on this policy, under a
written contract or agreement currently in effect, or
becoming effective during the term of this policy. The
additional insured status will not be afforded with
respect to liability arising out of or related to your
activities as a real estate manager for that person or
organization.

Information required to complete this Schedule, if not shown above, will be shown in the Declarations.

A. Section II - Who Is An Insured is amended to
include as an additional insured the person(s) or
organization(s) shown in the Schedule, but only
with respect to liability for "bodily injury", "property damage" or "personal and advertising injury"
caused, in whole or in part, by:

1. Your acts or omissions; or

2. The acts or omissions of those acting on your
behalf;
in the performance of your ongoing operations for
the additional insured(s) at the location(s)
designated above.

However:

1. The insurance afforded to such additional
insured only applies to the extent permitted
by law; and

2. If coverage provided to the additional insured
is required by a contract or agreement, the
insurance afforded to such additional insured
will not be broader than that which you are
required by the contract or agreement to
provide for such additional insured.

B. With respect to the insurance afforded to these
additional insureds, the following additional
exclusions apply:

This insurance does not apply to "bodily injury" or
"property damage" occurring after:

1. All work, including materials, parts or
equipment furnished in connection with such
work, on the project (other than service,
maintenance or repairs) to be performed by
or on behalf of the additional insured(s) at the
location of the covered operations has been
completed; or
CG 20 10 12 19 © Insurance Services Office, Inc., 2012 Page 1 of 2 EXHIBIT 2

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6/16/2026

EXHIBIT 2

City Council
15 –
211
6/16/2026

Page 1 of 18 ends

AGREEMENT UNDER THE WORKFORCE INNOVATION AND OPPORTUNITY ACT THIS SUBAWARD AGREEMENT, made and entered into this _1st day of July, 2026, by and between the City of Santa Ana, a charter city and municipal corporation duly organized and existing under the Constitution and laws of the State of California ("CITY and Taller San Jose Hope Builders , a non -profit corporation identified by the ir assigned Unique Entity Identifier (UEI) Number N5KLG1YNLVS6 ("SUBRECIPIENT").

RECITALS:

A. CITY has been designated a Local Workforce Development Area (LWDA) under the Workforce Innovation and Opportunity Act of 2014, Public Law 1-113-128 ("the Act") , Catalog of Federal Domestic Assistance (CFDA) Number 17.259 and Federal Award Identification Number (FAIN) AA253421455A6.

B. The State of California has created the LWDA to administer the Act programs operated by the State of California pursuant to the Act.

C. As a L WDA, CITY is entitled to receive federal funds to establish programs to increase the em ployment, retention and earnings of Participants, and increase occupational skills attainment by Participants, and as a result, improve the quality of the workforce, reduce welfare dependency, and enhance the productivity and competitiveness of the nation (“said program”).

D. On April 1, 2025, the City issued a Request for Proposal No. 25 -019A (“RFP”) by which it sought youth serving organizations to become members of the Youth Service Provider Network, referred to as Youth Service Provi ders (YSPN) to deliver a youth program for the City.

SUBRECIPIENT submitted a responsive proposal that was selected by the City. A copy of SUBRECIPIENT’s proposal is incorporated herein by reference as if set forth in full.

SUBRECIPIENT is experienced in operating workforce development programs for at -risk youth that provide preparation for secondary and post -secondary education, occupational training, and employment skills for entry into the labor market.

E. SUBRECIPIENT is willing to operate said program pursuant to the Act and California law.

WHEREFORE, for and in consideration of the respective and mutual covenants and promises hereinafter contained and made, and subject to all the terms and condi tions hereof, the parties hereto do hereby agree as follows:

I.

SUBRECIPIENT'S OBLIGATIONS
A. SUBRECIPIENT agrees to provide the following services pursuant to said program, as more specifically set forth in SUBRECIPIENT'S Program Narrative contained in "Exhibit A", as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) per 2 CFR §200.332(b)(1)(ix), and in the Performance Indicators contained in “Exhibit B”, per 2 CFR EXHIBIT 3

City Council
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212
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Page 2 of 18 ends

§200.332(e) and 2 CFR §200.328, both attached hereto and by this reference i ncorporated herein.

SUBRECIPIENT'S failure to provide said services may be grounds for CITY to readjust the level of payment to SUBRECIPIENT otherwise provided for hereinafter.

B. SUBRECIPIENT agrees to provide benefits to individuals who participate in the activities and services funded by this Agreement (" Participants") in accordance with the standards and requirements set forth in the Act.

C. SUBRECIPIENT agrees to perform the services set forth herein in a professional, timely and diligent manner.

D. SUBRECIPIENT shall provide wages and benefits to Participants in accordance with the standards and requirements of the Act, including Section 181 of the Act.

E. SUBRECIPIENT shall adhere to the Labor Standards described in the Act, including Section 181 of the Act.

F. SUBRECIPIENT agrees to comply with the "Complaint Handling Procedures Under the WIOA”, attached hereto as "Exhibit C" and incorporated herein as though fully set forth in 20 CFR 658.411. SUBRECIPIENT shall advise Participants of their rights to file complaints under the Act and the procedures for resolution of any complaints. CITY's procedures for handling complaints alleging a violation of the Act, regulations, grants, or other agreements under the A ct shall be followed and any decision of CITY, the State or the federal government relating to the complaint shall be binding and followed by SUBRECIPIENT. SUBRECIPIENTS who are employers shall operate a grievance system that incorporates CITY's procedures for resolution of complaints relating to the terms and conditions of employment; these procedures shall be approved in writing by CITY.

G. As a condition of this award of financial assistance under the Act to SUBRECIPIENT from CITY, SUBRECIPIENT assures, with respect to operation of all programs or activities funded with funds provided pursuant to the Act, and all agreements or arrangements to carry out such programs or activities, that it will comply fully with the nondiscrimination and equal opportunity provisions of the Act (Section 188) and compliance with Equal Employment Opportunity provisions in Executive Order (E.O.) 11246, as amended by E.O. 11375 and supplemented by the requirements of 41 CFR Part 60 ; the Nontraditional Employment for Women Act of 1991; Title VI of the Civil Rights Act of 1964, as amended; section 504 of the Rehabilitation Act of 1973, as amended; the Age Discrimination Act of 1975, as amended; the Americans with Disabilities Act of 1990; and with all applicable requirements impose d by or pursuant to regulations implementing those laws, including, but not limited to, 29 CFR Parts 33 and 37. The United States, the State of California and CITY have the right to seek judicial enforcement of this assurance.

H. SUBRECIPIENT agrees that no Participant(s) shall commence training prior to the approval of funding pursuant to Section 123 of the Act.

I. SUBRECIPIENT agrees to the following accounting, monitoring, auditing, and review requirements:

1. SUBRECIPIENT agrees to maintain such r ecords and submit such EXHIBIT 3

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reports, data and information, on the form and containing such information, at such times as CITY may request or require regarding the performance of SUBRECIPIENT'S services or activities, costs or other data, including but not limit ed to, Participants' attendance, payroll records and job duty statements.

2. SUBRECIPIENT agrees to forward to the Santa Ana W ORK Center Administrative Office, 801 W. Civic Center Dr ., Suite 200, Santa Ana, California 92701 completed Workforce Innovation and Opportunity Act Application form and supporting documents; a complete Workforce Innovation and Opportunity Act Enrollment; any subsequent updates; Workforce Innovation and Opportunity Act Youth Test Scores form; Workforce Innovation and Opportunity Act Exit form upon completion/termination of active enrollment of Participant; and the Workforce Innovation and Opportunity Act Follow-Up form within 15 days following 30, 60, 90, 180, 270, and 360 days of exit. SUBRECIPIENT agrees to enter information on the State of California’s CalJobs database system as instructed and requested by the Santa Ana WORK Center Administration.

3. CITY, the State of California and the United States government and/or their representatives shall have access for purposes of monit oring, auditing and examining of SUBRECIPIENT'S activities, performance , books, documents, papers, records of SUBRECIPIENT SUBRECIPIENTs, bookkeepers, accountants, employees and Participants related to this Agreement. Such agencies or representatives shal l also schedule on -site monitoring at their discretion. Monitoring activities may also include, but are not limited to, questioning employees and Participants and entering any premises or onto any site in which any of the services or activities funded her eunder are conducted or in which any of the records of SUBRECIPIENT are kept (2 CFR §200.330). Nothing herein shall be construed to require access to any privileged or confidential information as set forth in federal or state law.

4. In the event SUBRECIPIENT does not make the above -referenced documents available within the City of Santa Ana, California, SUBRECIPIENT agrees to pay all necessary and reasonable expenses incurred by CITY in conducting any audit at the location where said records and books of account are maintained.

5. All accounting records and evidence pertaining to all costs of SUBRECIPIENT and all documents related to this Agreement shall be kept available at the location where SUBRECIPIENT conducted the program, as well as in the County of Orange, for the duration of this Agreement and thereafter for three (3) years after completion of an audit.

Records which relate to (a) complaints, claims, administrative proceedings or litigation arising out of the performance of this Agreement, or (b) costs and expenses of this Agreement to which CITY, the State of California or the United States Government take exception, shall be retained beyond the three (3) years until resolution of disposition of such appeals, litigation, cl aims, or exceptions.

J. Without prejudice to any other section of this Agreement, SUBRECIPIENT shall, where applicable, maintain the confidential nature of information provided to it concerning Participants in accordance with the requirements of federal and state law. Notwith standing the foregoing, SUBRECIPIENT agrees to submit to CITY, the State of California and/or the United States Government or their representatives, all records requested for administrative purposes, including audits, examinations, monitoring and verificat ion of records submitted by SUBRECIPIENT, costs EXHIBIT 3

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incurred and services rendered hereunder.

K. SUBRECIPIENT agrees to complete a monthly Invoice form showing in detail the amount of money already expended by SUBRECIPIENT hereunder, as this is a cash reimbursement contract. Accounting records must be supported by such source documentation as invoices, bills, statements, proof of payment , such as cancelled checks, payment confirmat ions, account statements , paid bills, payroll records, time and attendance records, and contract and subgrant award documents (2 CFR §200.101(b)(2)) . SUBRECIPIENT agrees to submit the above -stated documents to the W DB Administrative Office, 801 W. Civic Center Dr., Suite 200 , Santa Ana, California, 92701, by the tenth (10th) day of t he month following the month in which SUBRECIPIENT'S services are performed.

Should SUBRECIPIENT fail to deliver said documents to CITY within thirty (30) days of said deadline, CITY shall provide SUBRECIPIENT with written notice of such deficiency. If s aid deficiency is not corrected within thirty (30) days of mailing such written notice, CITY shall have the option to deobligate SUBRECIPIENT’s funds and cancel this Agreement by giving SUBRECIPIENT ten (10) days written notice thereof. SUBRECIPIENT shall either return to the CITY excess revenues over costs or use such excess revenues as program income for additional training activities authorized under the Act.

L. SUBRECIPIENT agrees to expend all funds in accordance with all applicable federal, state and local laws and regulations. SUBRECIPIENT also agrees to provide , at SUBRECIPIENT'S own expense, supplies and other costs of said PROGRAM.

M. SUBRECIPIENT shall arrange independently for an audit that includes WIOA funds received from CITY, in accordance with the Act, 2 CFR 200.500 et seq. SUBRECIPIENT shall submit one original of each required audit report to CITY within thirty (30) days after the date received by SUBRECIPIENT. Should SUBRECIPIENT fail to comply with these require ments, CITY may, at its option, withhold payment of funds, disallow funds, or suspend additional grant funds.

N. SUBRECIPIENT shall not expend funds pursuant to this Agreement to provide services to any Participant where costs of training are paid for by any other person or entity.

O. SUBRECIPIENT shall comply with the provisions of Uniform Guidance 2 CFR Part 200 of the U.S. Office of Management and Budget (OMB) and all other applicable federal statutes and executive orders and their implementing regulations, including regulations at 29 CFR Part 97.

P. SUBRECIPIENT shall comply with the requirements of federal regulations found at 29 CFR Part 93, which provide that no appropriated funds may be expended by the recipient of a federal contract, grant, loan or cooperative agreement to pay any person for influencing or attempting to influence an officer or employee of any agency, member of Congress or an officer or employee of a member of Congress in connection with awarding of any federal contract, the making of any federal grant or loan, entering into any cooperative agreement and the extension, renewal, amendment or modification of any federal contract, grant, loan or cooperative agree ment.

SUBRECIPIENT shall sign a C ertification Regarding Lobbying to that effect in a form as set forth in "Exhibit E," attached hereto and by this reference incorporated herein. SUBRECIPIENT shall submit said signed Certification to CITY prior to performing any of its obligations under this Agreement and prior to any obligatio n arising on the part of CITY to pay any sums to SUBRECIPIENT under the terms and conditions of this Agreement.

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Q. SUBRECIPIENT agrees to provide a drug-free work place and to execute a Drug Free Workplace Certification as set forth in "Exhibit F" attached hereto and incorporated herein by this reference.

R. SUBRECIPIENT, in accordance with the Child Support Compliance Act, recognizes and acknowledges the importance of child and family support obligations and shall fully comply with all state and federal laws relating to child and family support enforcement, including, but not limited to: disclosure of information and compliance with earnings assignment orders, as provided in Chapter 8 (commencing with Section 5200) of Part 5 of Division 9 of the state Family Code; and, to the best of its knowledge is fully complying with the earnings assignment orders of all employees and is providing the names of all new employees to the New Employee Registry maintained by the California Employment Development Department (EDD).

S. SUBRECIPIENT agrees to comply with all applicable provisions of the Act, and all applicable federal regulations, including , but not limited to , the Code of Federal Regulations, Subtitle A —Office of Management and Budget Guidance for Grant s and Agreements, as well as all applicable state and local regulations.

T. SUBRECIPIENT agrees to remain in compliance with the Certification Regarding Debarment (“Exhibit G ”), as required by the regulations implementing Executive Order 12549, Debarment and Suspension, (2 CFR Part 180).

U. SUBRECIPIENT agrees to provide priority of services for veterans and eligible spouses pursuant to 20 CFR Part 1010 , and the regulations implementing priority of service for veterans and eligible spouses in Departm ent of Labor job training programs under the Jobs for Veterans Act published at 73 Fed.Reg. 78132 on December 19, 2008.

V. SUBRECIPIENT acknowledges that the official name for the statewide system of providing employment and training through the WIOA partnerships and various other local programs is “America’s Job Center”. To achieve the goals of this grant, it is important that the public has a quick and easy method to identify that the projects or programs they are taking part in are part of the “Ameri ca’s Job Center”. SUBRECIPIENT agrees to place the America’s Job Center logo, in accordance with the State of California guidelines for such use, on all public materials , such as statements, press releases, brochures, advertisements, reports and other doc uments describing projects or programs funded in whole or in part with WIOA funds. When the America’s Job Center logo is used, SUBRECIPIENT may accompany it with the following statement, “The (Program Name) is a proud partner of the America’s Job Center network”. SUBRECIPIENT shall not use the America’s Job Center logo in any manner that would imply that the State of California endorses a commercial product, service or activity.

II.

CITY'S OBLIGATIONS

A. On May 28, 2025 , the CITY was awarded a Departm ent of Labor Workforce Innovation and Opportunity Act youth grant of $817,644.00 for fiscal year 2025-2026, with a two-year performance period which dictates that 100% of the funding allocation must be obligated before the contact window closes on June 30, 2027. CITY agrees to pay to SUBRECIPIENT when, if and to the EXHIBIT 3

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extent federal funds are received under the provisions of the Act a sum not to exceed $200,000.00 for SUBRECIPIENT'S performance in accordance with the Budget attached hereto as " Exhibit D" and incorporated herein by reference, during the period of this Agreement for Program Year 2026-2027.

Said sum shall be paid after CITY receives invoices sub mitted by SUBRECIPIENT as provided hereinabove.

B. Pursuant to 2 CFR §200.332(b)(4), the Indirect Cost Rate for the SUBRECIPIENT’s award shall be an approved federally recognized indirect cost rate negotiated between the SUBRECIPIENT and the Federal go vernment, or, if no such rate exists, either a rate negotiated between the CITY and the SUBRECIPIENT, or a de minimis indirect cost rate as defined in 2 CFR §200.414(f) Indirect (F&A) costs.

C. SUBRECIPIENT has the ability to adjust line item amounts in t he budget with the approval of the Executive Director, so long as the total Budget amount does not increase.

D. CITY agrees to provide for on -site monitoring reviews of said program operation at least annually. In addition, monthly desktop reviews of per tinent information will be conducted.

E. CITY has the right to de -obligate the funds hereunder , and take such funding back from SUBRECIPIENT, due to any of the following reasons: (a) lack of performance by SUBRECIPIENT; (b) lack of fiscal account ability of SUBRECIPIENT; or (c) decrease in available funding.

III.

TERM OF AGREEMENT

A. This Agreement shall commence on July 1, 202 6, and all duties arising under this Agreement shall have been performed by June 30, 2027. The Term of this Agreement m ay be extended by a writing executed by the City Manager and the City Attorney. SUBRECIPIENT acknowledges and agrees that it must provide follow -up services for one (1) year after the Term, whether funded or not.

B. SUBRECIPIENT agrees to comply with the closeout procedures detailed in 2 CFR §200.343, including the following:

1. SUBRECIPIENT must submit, no later than ninety ( 90) calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award;

2. Unless the CITY authorizes an extension, SUBRECIPIENT must liquidate all obligations incurred under the Federal award not later than ninety (90) calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award;

3. SUBRECIPIENT must promptly refund any balances of unobligated cash that the CITY paid in advance or paid and that is not authorized to be retained by SUBRECIPIENT for use in other projects (See OMB Circular A-129 and 2 CFR §200.345);

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4. SUBRECIPIENT must account for any real and personal property acquired with Federal funds or received from the Federal government in accordance with 2 CFR §§200.310-200.316 and 2 CFR 200.329; and,

5. The CITY should complete all closeout actions for the Federal award no later than one year after receipt and acceptance of all required final reports.

IV.

INDEPENDENT CONTRACTOR

Consultant shall, during the entire term of this Agreement, be construed to be an independent contractor and not an employee of the City. This Agreement is not intended nor shall it be construed to create an employer-employee relationship, a joint venture relationship, or to allow the City to exercise discretion or control over the professional manner in which Consultant performs the services which are the subject matter of this Agreement; however, the services to be provided by Consultant shall be provided in a manner consistent with all applicable standards and regulations governing such services. Consultant shall pay all salaries and wages, employer's social security taxes, unemployment insurance and similar taxes relating to employees and shall be responsible for all applicable withholding taxes.

V.

WORKER'S COMPENSATION AND EMPLOYER'S RIGHTS

A. SUBRECIPIENT shall use appropriate funds received from CITY to provide workers' compensation to all those hired by SUBRECIPIENT under this Agreement.

B. SUBRECIPIENT shall have the right to hire, dismiss, or promot e its employees or contract personnel hired under this Agreement so long as its hiring or dismissal policy or standard does not violate Title VII of the Civil Rights Act of 1964, Fair Labor Standards Act of 1938, or any other applicable law, and SUBRECIPIENT maintains itself as an Equal Opportunity employer.

VI.

APPLICABLE GUIDELINES

A. The parties hereto agree that SUBRECIPIENT shall comply with all applicable federal and state laws and regulations, including, but not limited to the Performance Indicators (Exhibit B ) and general program requirements described in Sections 2 and 116 of the Act , and applicable regulations, and the U.S. Department of Labor guidelines and regulations, including amendments or revisions made during the terms of this Agreement. Said applicable laws are hereby incorporated by reference and made part of this Agreement as though fully set forth herein.

B. SUBRECIPIENT also assures and certifies that:

1. SUBRECIPIENT acknowledges and confirms that the U.S. Department of Labor has established six (6) performance indicators for youth: (a) Percent of Participants who are in education/training activities, or in unsubsidized employment during the 2 nd quarter after exit ; (b) Percent of Participants who are in education/training, or in unsubsidized employment during the 4 th quarter after exit ; (c) the median earnings of Participants in unsubsidized employment during the 2 nd quarter after exit; (d) Percent of Participants who obtain recognized postsecondary credential or EXHIBIT 3

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secondary diploma during participation or within 1 year after exit; (e) Percent of Participants who, during the program, are in education or training that leads to a recognized postsecondary credential or employment and who are achieving measurable skill gains; and , (f) e ffective in serving employers .

SUBRECIPIENT agrees to implement and shall meet any additional performance indicators that may be subsequently required by the Workforce Innovation and Opportunity Act or by any other Federal, State, and local law.

2. SUBRECIPIENT shall comply with Title VII of the Civil Rights Act of 1964 (P.L. 88-352) and in accordance with Title VII of the Act, requiring that no person shall, on the grounds of race, color, religion, sex, age, disability or national origin be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under this Agreement.

3. SUBRECIPIENT shall comply with any and all federal laws limiting the political activity of employees hired under this Agreement.

4. SUBRECIPIENT shall comply with the requirements that no program under the Act shall involve political activities.

5. RECORD INSPECTION. SUBRECIPIENT shall provide the U.S.

Department of Labor and the Controller General, by and through any authorized representative, as well as the WIB Administrative Office, access to and the right to examine all records, books, papers or documents relating to the accounting and use of funds under this Agreement for a three -year period from and after the effective date of this Agreement.

6. No person with responsibilities in the operation of any program under the Act shall discriminate with respect to any program Participant or any application for participation in such program because of race, religion, color, national origin, sex, political affiliation or beliefs.

7. SUBRECIPIENT shall maintain appropriate standards for health and safety in work and training situations.

8. SUBRECIPIENT shall comply with general provisions, assurances, and execute the Assurances and Certifications attached hereto as "Exhibit H" and incorporated herein.

9. EQUAL OPPORTUNITY. Any literature distributed by
SUBRECIPIENT for the purpose of apprising businesses, Participants, or the general public of its programs under this Agreement shall state that its programs are supported by the City of Santa Ana and the Santa Ana Workforce Investment Board, and shall state that the program is an “equal opportunity employer/program” and that “auxiliary aids and services are available upon request to individuals with disabilities.”

10. Based on the population eligible to be served, or likely to be directly affected by the WIOA program or activity, the services or information may need to be provided in a language other than English in order to allow such population to be eff ectively informed about or able to participate in the program or activity. Pursuant to 29 CFR 37.35, SUBRECIPIENT must take reasonable steps to provide services and information in appropriate languages after considering the scope of the program or activity, and the size and concentration of the population that needs services or information in a language other than English.

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11. SUBRECIPIENT certifies that all property, finished or unfinished documents, data, studies and reports prepared or purchased unde r this Agreement, will be disposed of in accordance with the direction of the CITY. In addition, any tools and/or equipment furnished to the SUBRECIPIENT by the CITY and/or purchased by the SUBRECIPIENT with funds pursuant to this Agreement, will be limit ed to use within the activities outlined in this agreement and will remain the property of the United States Government and/or CITY. Upon termination of this Agreement, SUBRECIPIENT will immediately return such tools and/or equipment to the CITY or dispos e of them in accordance with the direction of the CITY.

12. SUBRECIPIENT certifies that this Agreement does not provide for the advancement or aid to any religious sect, church or creed, or sectarian purpose , nor does it help to support or sustain any sch ool, college, university, hospital or other institution controlled by any religious creed, church, or sectarian denomination, as specified by Article XVI, Section 5, of the Constitution of the State of California, regarding separation of church and state.

13. PATENT, COPYRIGHTS AND RIGHTS IN DATA. The
SUBRECIPIENT will disclose to the CITY any invention, written product, or computer program developed, or data assembled , as a result of performance of work under this Agreement , within seventy-four (74) days of invention, development or assembly. The CITY, State of California, and U.S. Department of Labor will have the right to patent any invention and copyright any written product or computer program or data generated by SUBRECIPIENT. Upon written req uest, SUBRECIPIENT will transfer all pertinent information, specifications and right, title and interest to the designated agency.

14. INVENTIONS, PATENTS AND COPYRIGHTS.

A. Reporting Procedure. If any project produces patentable items, patent rig hts, processes, or inventions in the course of work under a U.S. Department of Labor (DOL) grant or agreement, the SUBRECIPIENT shall report the fact promptly and fully to the CITY. The CITY shall report the fact to the Grant Officer, at the DOL. Unless there is a prior agreement between the CITY and the DOL and its representative on these matters, the DOL shall determine whether to seek protection on the invention or discovery. The DOL and its representative shall determine how the rights in the invention or discovery, including rights under any patent issued thereon, will be allocated and administered in order to protect the public interest consistent with the "Governmental Patent Policy" (President's Memorandum for Heads of Executive Departments and Ag encies, August 23, 1971, and Statement of Government Patent Policy as printed in 36 FR 16889).

B. Copyright Policy.

1. Unless otherwise provided in the terms of the grant or agreement, when copyright - able material is developed in the course of or under a DOL Grant or agreement, the author and the CITY which developed the work is free to copyright material or to permit others to do so. The SUBRECIPIENT and the Workforce Development Board (W DB) shall have a royalty -free, nonexclusive and irrevocable licens e to reproduce, publish, use and to authorize others to use all copyrighted material.

2. The DOL reserves a royalty -free, nonexclusive, and irrevocable license to reproduce, publish or otherwise use, and to authorize others to use, for Federal Governm ent purposes:

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(a) The copyright in any work developed under any grant, sub -grant, or contract under a grant or subgrant; (b) Any right of copyright to which a grantee, subgrantee or a SUBRECIPIENT purchases ownership with grant support; and , (c) SUBRECIPIENT shall comply with the requirements of 29 CFR § 97.34.

C. Rights to Data. The DOL and the CITY shall have unlimited rights to any data first procured or delivered under this Agreement.

15. CLEAN AIR / CLEAN WATER ACT. If the grant hereunder exceeds $100,000, SUBRECIPIENT must comply with Section 306 of the Clean Air Act [(42 USC 7606 ]; Section 508 of the Clean Water Act (33 USC 1368); Executive Order 11738 and Environmental Protection Agency (“EPA”) regulations (40 CFR Part 35) as any may n ow exist or be hereafter amended. Under these laws and regulations, the SUBRECIPIENT assures that:

(a) No facility to be utilized in the performance of the proposed grant has been listed on the EPA List of Violating Facilities;

(b) It will notify CITY prior to award of the receipt of any communication from the Director, Office of Federal Activities, U.S. EPA, indicating that a facility to be utilized for the grant is under consideration to be listed on the EPA List of Violating Facilities; and,

(c) It will notify t he CITY and the EPA about any known violation of the above laws and regulations.

16. SUBRECIPIENT agrees to adhere to the following STANDARDS OF CONDUCT:

a. General Assurance. Every reasonable course of action will be taken by SUBRECIPIENT in order to maintain the integrity of this expenditure of public funds and to avoid favoritism. This Agreement will be administered in an impartial manner, free from errors to gain personal, financial , political gain. SUBRECIPIENT, its officers and employees, in administering this Agreement, will avoid situations which give rise to a suggestion that any decision was influenced by prejudice, bias, special interest or desire for personal gain.

b. Employment of Former State or CITY Employees. SUBRECIPIENT will ensure that any of its employees who were formerly employed by the State of California or CITY, in a position that could have enabled such individuals to impact policy regarding or implementation of programs covered by this Agreement, will not be assig ned to any part or phase of the activities conducted pursuant to this Agreement for a period of not less than two (2) years following the termination of such employment.

c. Conducting Business Involving Relatives. No relative by blood, adoption or marriage of any executive or employee of SUBRECIPIENT will receive favorable treatment when considered for enrollment in programs provided by, or employment with, SUBRECIPIENT.

d. Conducting Business Involving Close Personal Friends and Associates . Executives and employees of SUBRECIPIENT will be particularly aware of the varying degrees of influence that can be exerted by personal friends and associates and, in administering this Agreement, will exercise due EXHIBIT 3

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diligence to avoid situations which give rise to an assertion that favorable treatment is being granted to friends and associates. When it is in the public interest for SUBRECIPIENT to conduct business with a friend or associate of an executive or employee of SUBRECIPIENT, an elected official in the area or a voting or non -voting member of the Workforce Investment Board (WIB), a permanent record of the transaction will be retained.

e. Avoidance of Conflict of Economic Interest . No executive or employee of SUBRECIPIENT elected official in the area, or voting or non-voting member of a WDB, will solicit or accept money or any other consideration from a third person, for the performance of an act reimbursed in whole or part by SUBRECIPIENT or CITY. Supplies, materials, equipment or services purchased with Agreement funds will be used solely for purposes asserted or allowed under this Agreement. No voting member of the WDB will cast a vote on the provision of services or vote on any matter which would provide direct financial benefit to that member or any business or organization which the member directly represents.

f. Salary and Bonus Limitations . All Subrecipients of WIOA program funds are required to comply with federal requirements regarding the limitations on salary and bonus payments in accordance with Public Law 109-149, Section 503.

VII.

HOLD HARMLESS

A. SUBRECIPIENT shall indemnify and save harmless CITY, its officers, agents and employees, from and against any and all damages to property or injuries to or death of any person or persons, including property and employees or agents of CITY, and shall defend, indemnify and save harmless CITY, its officers, agents and employees, from any and all claims, demands, suits, actions or proceedings of any kind or nature, including, but not by way of lim itation, workers' compensation claims, resulting from or arising out of the negligent acts, errors or omission of SUBRECIPIENT, its employees or subcontractors.

B. SUBRECIPIENT shall indemnify and save harmless CITY, its officers, agents and employees, from and against any and all damages to property or injuries to or death of any person or persons, including property and employees or agents of CITY, and shall defend, indemnify and save harmless CITY, its officers, agents and employees, from and against any and all claims, demands, suits, actions or proceedings therefore, resulting from or arising out of the intentional or malicious acts of SUBRECIPIENT, its employees or subcontractors.

VIII.

INSURANCE

SUBRECIPIENT shall procure and maintain for the dur ation of the agreement, the following insurance coverages:

MINIMUM SCOPE AND LIMIT OF INSURANCE

SUBRECIPIENT shall maintain limits of insurance coverage in the following minimum amounts and shall be at least as broad as:

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1. Commercial General Liability (CG L): Insurance Services Office Form CG 00 01 covering CGL on an “occurrence” basis, including products and completed operations, property damage, bodily injury and personal & advertising injury with limits no less than $1,000,000 per occurrence and $2,000,000 aggregate.

2. Sexual Abuse or Molestation Liability (SAML) : If the CGL policy referenced above is not endorsed to include affirmative coverage for sexual abuse or molestation, SUBRECIPIENT shall obtain and maintain a policy covering Sexual Abuse and Molest ation with a limit of no less than $1,000,000 per occurrence or claim.

3. Automobile Liability (AL) : Insurance Services Office Form CA 00 01 covering Code 1 (any auto), with combined single limits of $1,000,000. In the event SUBRECIPIENT does not maintain co mmercial automobile liability insurance, City will accept evidence of personal automobile insurance with existing limits, which can be lower than $1,000,000.

4. Workers’ Compensation (W/C) : as required by the State of California, with statutory limits, and Em ployer’s Liability Insurance with limit of no less than $1,000,000 per accident, per employee, per policy for bodily injury or disease. This requirement can be waived if SUBRECIPIENT has no employees.

If SUBRECIPIENT maintains broader coverage and/or high er limits than the minimums shown above, City requires and shall be entitled to the broader coverage and/or the higher limits maintained by SUBRECIPIENT. Any available insurance proceeds in excess of the specified minimum limits of insurance and coverage shall be available to City.

Other Insurance Provisions
The insurance policies are to contain, or be endorsed to contain, the following provisions:

1. CGL, SAML and AL policies: City of Santa Ana, its City Council, its officers, officials, employees, agents, and volunteers are to be covered as additional insureds with respect to liability arising out of work or operations performed by or on behalf of the SUBECIPIENT including materials, parts, equipment, and personnel furnished in connection with such work or operations.

2. All required insurance policies: Insurance company(ies) agrees to waive all rights of subrogation against City, its City Council, its officers, officials, employees, agents, and volunteers for losses paid under the terms of any policy which a rise from work performed by SUBRECIPIENT for City.

3. All required insurance policies: For any claims related to this contract, SUBRECIPIENT’s insurance coverage shall be primary and any insurance maintained by City, its City Council, its officers, officials, employees, agents, or volunteers shall not contribute with it.

4. All required insurance policies: A severability of interest provision must apply for all the additional insureds, ensuring that SUBRECIPIENT’s insurance shall apply separately to each insured against whom a claim is made or suit is brought, except with respect to the insurer’s limits of liability.

5. Each insurance policy required herein shall provide that coverage shall not be canceled, suspended, voided, reduced in coverage or in limits, non -renewed by the carrier, or materially changed except after thirty (30) days prior written notice has been given to City. Ten (10) days prior written shall be provided to City for policy cancellation or non -renewal due to non - payment.

6. Certificate Holder on eac h Evidence of Insurance certificate shall be: City of Santa Ana, Attention: Risk Management Division, 20 Civic Center Plaza , Santa Ana, CA 92701. The EXHIBIT 3

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name and location of event should be included in the Description of Operations section of each certificate.

Self-Insured Retentions
Self-insured retentions must be declared to and approved by the City. City may require SUBRECIPIENT to purchase coverage with a lower retention or provide proof of ability to pay losses and related investigations, claim administration, and defense expenses within the retention.

Acceptability of Insurers
Insurance is to be placed with insurers authorized to conduct business in the state of California with a current A.M. Best rating of no less than A:VII, unless otherwise acceptable to City.

Verification of Coverage
SUBRECIPIENT shall furnish City with original Certificates of Insurance including all required amendatory endorsements (or copies of the applicable policy language effecting coverage required by this clause) and a cop y of the Declarations and Endorsement Page of the CGL policy listing all policy endorsements to City before work begins. However, failure to obtain the required documents prior to the work beginning shall not waive Permittee’s obligation to provide them. C ity reserves the right to require complete, certified copies of all required insurance policies, including endorsements required by these specifications, at any time.

Claims Made Policies
If any of the required policies provide coverage on a claims-made basis:

1. The retroactive date must be shown and must be before the date of the contract or the beginning of work.

2. Insurance must be maintained and evidence of insurance must be provided for at least three (3) years after completion of work.

3. If coverage is canceled or non -renewed, and not replaced with another claims-made policy form with a retroactive dat e prior to the contract effective date, Company must purchase “extended reporting” coverage for a minimum of three (3) years after completion of work.

Subcontractors
SUBRECIPIENT shall require and verify that all sub -contractors maintain insurance meeting all the requirements stated herein, and SUBRECIPIENT shall ensure that City is an additional insured on insurance required from sub-contractors.

Special Risks or Circumstances
City reserves the right to modify these requirements, including limits, based on the nature of the risk, prior experience, insurer, coverage, or other special circumstances.

IX.

CORPORATE STATUS

All corporate SUBRECIPIENTs shall be in good standing, without suspension by the California Secretary of State, Franchise Tax Board or Internal Revenue Service. Any change in corporate status or suspension shall be reported immediately to CITY.

X.

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ASSIGNABILITY

None of the duties of, or work to be performed by, SUBRECIPIENT under this Agreement shall be subcontracted or assigned to any agency, consultant, or person without the prior written consent of CITY. SUBRECIPIENT must submit all subcontracts and other agreements that relate to this Agreement to CITY. SUBRECIPIENT acknowledges and agrees that it must follow procurement regulations for subrecipients (2 CFR §200.317). No subcontract or assignment shall terminate or alter the legal obligations of SUBRECIPIENT pursuant to this Agreement.

XI.

LAWS GOVERNING THIS AGREEMENT

In its performance under this Agreement, SUBRECIPIENT shall fully comply with the requirements of the following, whether or not otherwise referred to in this Agreement:

1. The Act and all applicable federal statutes, regulations, policies, procedures and directives, including but not limited to, 2 CFR Part 200 and 20 CFR Parts 651 and 654

2. All applicable State statutes, regulations, policies, procedures and directives;

3. All applicable CITY policies, procedures and directives;

4. All applicable local ordinances and requirements, including use permits and licensing;

5. Court orders applicable to its operation; and,

6. The terms and conditions of this Agreement.

If any of the foregoing is enacted, amended, or revised, SUBRECIPIENT will comply with such or will notify CITY after enactment or modification that it cannot so comply. CITY may thereupon terminate this Agreement, if necessary.

XII.

EXCLUSIVITY AND AMENDMENT OF AGREEMENT

This Agreement supersedes any and all other agreements, either oral or in writing, between the parties hereto with respect to the employment of SUBRECIPIENT by CITY, and contains all the covenants and agreements between the parties with respect to such employment. Each party to this Agreement acknowledges that no representations, inducements, promises or agreements, orally or otherwise, have been made by any party, or anyone acting on behalf of any party, which are not embodied herein, and that no other agreement or amendment hereto shall be effective unless executed in writing and signed by both CITY and SUBRECIPIENT.

XIII.

FRAUD

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SUBRECIPIENT shall immediately report to CITY all instances and facts concerning possible fraud, abuse or criminal activity relating to expenditure or receipt of funds under this Agreement.

XIV.

CONTINGENCY OF FUNDS

SUBRECIPIENT acknowledges that approval of and funding for this Agreement is contingent upon State approval, and funds received or obligated from the State of California to CITY.

If such approval of funds is not forthcoming, or is otherwise limited, CITY shall immediately notify SUBRECIPIENT. Within twenty (20) days of receipt of such notice, SUBRECIPIENT shall modify or cease operations as directed by CITY and negotiate necessary modification to this Agreement and/or reimbursement of costs incurred hereunder.

XV.

TERMINATION

A. This Agreement may be terminated by either party a t its sole discretion, upon thirty (30) days written notice to the other party. Notice shall be deemed served on the date of mailing. However, SUBRECIPIENT may not terminate this Agreement if undue hardship will result to any Participant.

B. In the ev ent SUBRECIPIENT defaults by failing to fulfill all or any of its obligations hereunder, CITY may declare a default and termination of this Agreement by written notice to SUBRECIPIENT, which default and termination shall be effective on a date stated in the notice which is to be not less than ten (10) days after certified mailing or personal service of such notice, unless such default is cured before the effective date of termination stated in such notice. If terminated for cause, CITY shall be relieved of further liability or responsibility under this Agreement, or as a result of the termination thereof, including the payment of money, except for payment for approved expenses incurred for services satisfactorily and timely performed prior to the mailing or service of the notice of termination, and except for reimbursement of (1) any payments made for services not subsequently performed in a timely and satisfactory manner, and (2) costs incurred by CITY in obtaining substitute performance.

XVI.

DISPUTES

Except as otherwise provided in this Agreement, any dispute concerning any question arising under this Agreement shall be decided by CITY. In such a case CITY shall reduce its decision to writing and mail or otherwise furnish a copy thereof to SUBRECIPIENT. The decision of the City shall be final and conclusive unless within thirty (30) calendar days from the mailing or delivery of such copy, CITY receives from SUBRECIPIENT written request to appeal said decision.

Procedures governing the appeal shall be prescribed by CITY and/or the State of California in accordance with the Act and all corresponding regulations and OMB circulars. Pending final disposition of the appeal, SUBRECIPIENT shall act in accordance with CITY's decision unless the dispute involves a change order.

XVII.

BREACH - SANCTIONS

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If, through any cause, SUBRECIPIENT violates any of the terms and conditions of this Agreement, and/or prior agreements whereby grant funds were received by SUBRECIPIENT pursuant to this Agreement, or if SUBRECIPIENT reports inaccurately or if any Audit Report makes disallowances, SUBRECIPIENT shall promptly remedy its acts or omissions and/or repay CITY all amounts due CITY as a result of SUBRECIPIENT's violation. For any such failures or violations, CITY shall also have the right at its sole discretion to either: (1) discontinue program support until such time as SUBRECIPIENT fulfills its obligations or remedies all violations of this Agreement or prior agreements; and/or (2) collect outstanding amounts as de termined by CITY due CITY by offsetting or debiting from current claims or invoices, if after thirty (30) days' written notice SUBRECIPIENT has failed to repay same or a repayment schedule has not been made; and/or (3) terminate this Agreement by giving wr itten notice to SUBRECIPIENT of such termination in accordance the notice provision in Paragraph XVIII herein below.

XVIII.

NOTICES

All notices, reports and correspondence between the parties hereto respecting this Agreement shall be in writing and depos ited in the United States Mail, postage prepaid, addressed as follows:

CITY: City of Santa Ana
Manager, WDB Administrative Office
P.O. Box 1988 (M-76)
Santa Ana, CA 92702

CLERK: City Clerk
City of Santa Ana
20 Civic Center Plaza (M-30)
P.O. Box 1988
Santa Ana, CA 92702-1988
Telefacsimile (714) 647-6956

SUBRECIPIENT: Taller San Jose Hope Builders
801 N. Broadway, Santa Ana 92701
Phone: (714) 543-5105

XIX.

MERGER

This Agreement, together with the attachments hereto, expresses the t otal understanding of the parties. There are no oral understandings of the parties or terms and conditio ns other than as stated herein.

XX.

VALIDITY

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The invalidity in whole or in part of any provision of this Agreement shall not void or affect the validity of any other provision of this Agreement.

XXI.

MISCELLANEOUS PROVISIONS

a. Each undersigned represents and warrants that its signature hereinbelow has the power, authority and right to bind their respective parties to each of the terms of this Agr eement, and shall indemnify CITY fully, including reasonable costs and attorney’s fees, for any injuries or damages to CITY in the event that such authority or power is not, in fact, held by the signatory or is withdrawn.

b. All Exhibits referenced herein and attached hereto shall be incorporated as if fully set forth in the body of this Agreement.

{Signatures on following page}

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IN WITNESS WHEREOF, the parties hereto have executed this Agreement the date and year first above-written.

ATTEST: "CITY"

_________________________ By: __________________________ Jennifer Hall Alvaro Nuñez
City Clerk City Manager

APPROVED AS TO FORM:

Sonia R. Carvalho “SUBRECIPIENT”
City Attorney

By: ____________________ By: ___________________________ Andrea N. Garcia Name: Shawna Smith
Senior Assistant City Attorney Title: Executive Officer Tax ID #: _EIN 59-3816355

RECOMMENDED FOR APPROVAL:

_________________________
Michael L. Garcia
Executive Director
Community Development Agency

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EXHIBIT A

Workforce Innovation & Opportunity Act
Youth Program Provider

Hope Builders
2026-2027

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Hope Builders’ Proposal

Experience/Qualifications

Description of Organization: Hope Builders empowers young adults in Orange County by providing mentorship, life skills, and job training that align with employer needs. Since 1995, Hope Builders has served as a pathway to opportunity, guiding disadvantaged young adults toward career success through comprehensive support and hands-on training. Recognizing that access to meaningful careers can significantly transform lives, the organization is dedicated to equipping Orange County's most vulnerable young adults with the skills and support needed to secure quality jobs with competitive wages, health benefits, safe work environments, stable schedules, and opportunities for advancement.

Each year, Hope Builders serves more than 200 diverse young adults and equips them with the essential technical and professional skills needed to thrive in the workforce. Programs in Clinical Medical Assisting (CMA), Child Development Careers (CDC), and Construction Training (CTP) provide industry-specific training while also addressing social and emotional barriers that may hinder long-term success.

Facility Addresses: Hope Builders has three facility locations:

1. CDC training is implemented at 801 N. Broadway, Santa Ana, CA 92701 (major cross streets: N. Broadway & E. Civic Center Dr.)

2. CTP training is implemented at 810 Poinsettia St N, Santa Ana, CA 92701 (major cross streets: Poinsettia St N & W. Washington Ave.)

3. CMA training is implemented at 100 N. Harbor Blvd, Unit 200, Anaheim, CA 92805 (major cross streets: N. Harbor Blvd & W. Lincoln Ave.)

The Santa Ana location at 801 N. Broadway also serves as Hope Builders' headquarters.

Hours of Operation: Hope Builders' hours of program operation are Monday–Friday, 8:00 AM– 4:30 PM for CDC and CMA, and 7:00 AM–3:00 PM for the Construction CTP. Administrative hours are Monday–Friday, 8:00 AM–4:30 PM.

Youth Friendly Characteristics of Facilities: Hope Builders' facilities are intentionally designed to be youth-friendly, creating a welcoming, safe, and supportive environment where young adults can thrive. The CDC program features a space modeled after a childcare center, allowing trainees to practice classroom management and caregiving skills in a realistic setting. The CMA program includes training spaces that mimic medical offices, equipping participants with experience in administrative and clinical procedures. The CTP facility is designed like an indoor construction site, complete with tools and materials that simulate actual job site conditions.

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These immersive environments ensure that trainees are well-prepared to transition seamlessly into the workforce.

Additionally, the training facilities have been designed to create warm and inviting learning environments, featuring artwork throughout the buildings and classrooms that resemble professional workstations, helping young adults prepare for the settings they will encounter in the workforce. To further support students, the facilities include study and meeting spaces, comfortable mentorship areas, and lunch areas equipped with microwaves. The CTP facility also features a coffee station and a basketball hoop, fostering camaraderie among trainees.

Beyond the physical environment, Hope Builders' staff is trained to provide a positive, encouraging atmosphere, helping youth overcome challenges and stay motivated in their career journeys. These elements combined make Hope Builders' facilities ideally suited to support young adults as they build confidence, develop skills, and prepare for successful futures.

Operating Budget & Sources of Revenue: Hope Builders has 30 years of experience managing multiple funding streams and a strong track record of income growth. The agency prioritizes diversifying its funding base to avoid reliance on a single revenue source. Hope Builders’ FY2026 consolidated budget is $4,476,487. Expected revenue includes $1,825,000 from individual contributions, $1,420,000 from grants, $630,000 from program service revenue, and $601,487 from Hope Builders Career Connections (HBCC), the organization’s social enterprise staffing agency (net of labor costs).

Description of Staff: Hope Builders has a total of 31 staff members and will dedicate a team of 11 staff members to this project to ensure comprehensive support and training for participants.

The assigned staff include 4 Training Supervisors to provide hard skills training. Additionally, 2 Employment Readiness Coordinators, 1 Employment Readiness Specialist, and 1 Employment Readiness Manager will focus on preparing youth for the workforce. Moreover, an Admissions Manager will oversee participant intake, a Grants Administrator will manage compliance and reporting, and a Director of Programs will provide leadership and strategic direction for program effectiveness.

Past WIA/WIOA Experience: Hope Builders served as a Workforce Investment Act (WIA) contractor for the City of Santa Ana from 2006 to 2015 and has been implementing Workforce Innovation and Opportunity Act (WIOA) services for the City of Anaheim since 2016.

Community Impact: Since 1995, Hope Builders has equipped more than 7,500 young adults with the skills and support needed to achieve economic stability. In FY2025, Hope Builders enrolled 282 young adults (106 of whom were Santa Ana residents) in its workforce training programs; and provided 254 with the hard and soft skills necessary to secure employment in construction, medical assisting, or child development. The program successfully placed 212 young adults into career pathways, defined as full-time employment that pays at least $2 above minimum wage, EXHIBIT 3

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includes employer-sponsored health benefits, and offers opportunities for advancement.

Additionally, 165 retained their jobs for at least six months.

Among the 282 participants enrolled in the previous fiscal year, 14% were parents, 15% had been involved in the justice system, 30% had experienced trauma specifically related to domestic violence or foster care emancipation, 60% were women, 96% were Hispanic/Latino, and 100% were low-income. Hope Builders also connected program graduates with over 100 employers across Orange County.

Proposed Program

Admissions & Readiness Assessment: Hope Builders will recruit out-of-school youth (ages 18- 24) who demonstrate a strong desire to turn their lives around. Before enrollment, candidates will undergo a vetting process to assess their readiness for the program. Prospective trainees must show commitment by submitting an application, completing an interview, passing a drug test, providing right-to-work documents, and taking the Test of Adult Basic Education (TABE).

During the admissions process, Hope Builders will use the IRIS assessment to evaluate youth across more than 100 behavioral mindsets and essential skills, including initiative, problem- solving, critical thinking, creativity, productivity, grit, and interpersonal skills. IRIS is then used to map career goals to performance targets, guiding a life skills curriculum that: (1) supports trainees in building foundational workplace behaviors; (2) helps staff identify and address skill gaps; and (3) provides ongoing feedback on attendance, punctuality, work habits, and employability. Findings from IRIS will inform weekly staff meetings, and trainees and support staff will set and review goals for personal and professional growth.

Once participants are enrolled, the training model will be implemented in four stages: (1) Job Skills, (2) Mentoring/Life Skills, (3) Links to Career & Education Pathways, and (4) Employment Services:

1. Job Skills: This stage provides trainees with essential industry-specific skills, including contextualized basic skills remediation to develop the reading and math competencies needed for success in their fields. CTP trainees will focus on algebra, geometry, and trigonometry for estimating costs, reading blueprints, and carpentry, while healthcare trainees will strengthen their medical vocabulary and dosage calculations. Instruction will be reinforced through worksheets, college-level books, lectures, and hands-on learning. This phase will also include a weekly stipend and financial assistance for childcare and transportation. Trainees will be required to show up every day, on time, and dressed professionally for careers in these industries:
a. Construction, a 12-week pre-apprenticeship program that teaches construction fundamentals, construction theory, daily math and leadership development; and, b. Healthcare, which incorporates HIPAA Compliance in two fields:

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i. Clinical Medical Assisting (24 weeks): Prepares trainees to measure vital signs, assist physicians with procedures, administer medications and injections, record electrocardiograms, draw blood, and complete records to support medical staff.

Training includes a 160-hour practicum at a doctor’s office or medical clinic. ii. Child Development Careers (6 weeks): Prepares graduates to work in schools and clinics as Behavioral Technicians, Para-educators, Instructional Aides, or Early Childhood Assistant Teachers.

2. Mentoring/Life Skills: Hope Builders will provide comprehensive wraparound support services to help trainees successfully transition into the workforce. These services will include individualized case management and employment readiness support. Each trainee will be assigned an Employment Readiness Specialist/Coordinator to provide guidance in overcoming obstacles to program completion and employment. Throughout the training, participants will work closely with an Employment Readiness Specialist/Coordinator, to address employment barriers and develop essential workplace behaviors such as accountability, initiative, productivity, grit, and leadership.

Using IRIS assessment results, specialists will create individualized service plans with tailored goals. In addition to case management, trainees will receive weekly life skills instruction covering social and emotional wellness, healthy behaviors, technological literacy, financial responsibility, and educational achievement.

Additionally, participants receive weekly Employment Readiness workshops and coaching sessions to develop essential job search skills and workplace professionalism.

Training will cover interview preparation, resume writing, networking, professional presentation, and career exploration. Sessions will also focus on telephone/video conferencing techniques, dressing for success, and identifying employment pathways.

3. Links to Career & Education Pathways: Hope Builders, in partnership with the Rancho Santiago Community College District, will offer trainees the opportunity to earn post- secondary credentials. The Career Readiness team will conduct weekly sessions to guide participants in creating resumes, setting up professional email accounts, conducting job searches, dressing professionally, and practicing interview skills. To expand career awareness, guest speakers from industries such as Providence, Kaiser Permanente, Hoag Hospital, ABA Enhancements, and 24HRC will introduce trainees to potential career pathways. Additionally, trainees will participate in industry field trips, including visits to the Orange County Carpenter's Union, ABC Craft Championship, and AGC, providing hands-on exposure to various career opportunities.

4. Employment Services: Through its social enterprise staffing agency, Hope Builders Career Connections (HBCC), participants will be supported to secure, maintain, and advance in their careers.

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Program Objectives: Hope Builders aims to equip youth with the skills, resources, and support needed to achieve long-term career success. The program's primary objectives align with key WIOA performance goals:

1. Measurable Skills Gains – CMA Trainees earn a Vocational Medical Certificate of Completion (non-credit) from Santiago Canyon College, American Heart Association BLS Certification, HIPAA and PPE Training Certificates, OSHA Certifications in Bloodborne Pathogens, Hazard Communication, Workplace Violence Prevention, and Hope Builders’ Certificate of Completion.

CDC Trainees earn a 40-Hour Behavior Technician Training Certificate, American Heart Association Heartsaver Pediatric First Aid & CPR Certification, California Mandated Reporter Certificate, and Hope Builders’ Certificate of Completion.

CTP Trainees earn MC3 Certification, Career Technical Education Certification through Santa Ana College, OSHA 10-Hour Certification, American Heart Association First Aid & CPR Certification, and Hope Builders’ Certificate of Completion.

Additionally, program staff will support trainees in furthering their education through employer-sponsored training programs, such as Associated Builders and Contractors, Associated General Contractors, or certificate and degree programs at local community colleges. At least 59% of youth will attain a recognized post-secondary credential through training AND achieve measurable skills gains.

2. Credential Attainment – All program participants will receive at least 12 hours of Education Pathways curriculum, designed to strengthen study skills, introduce career ladders and post-secondary pathways, and provide guidance on accessing financial aid and scholarships. At least 62% of youth will attain a Credential/Diploma/Certificate within 1 year after exit.

3. Employment or Placement Rate for Youth – Hope Builders will provide job preparation workshops, job fair participation, resume support, referrals, and job coaching to connect youth to employment opportunities. Additionally, trainees who complete Hope Builders' skills training academies will be linked to educational and training pipeline programs at local community colleges, career technical schools, and apprenticeship programs. Youth identified as needing basic literacy and numeracy remediation will receive at least 25 hours of tutoring and other services alongside their vocational training. At least 69% of youth will secure employment or enroll in postsecondary education by the second quarter after exit, with 62% by the fourth quarter.

4. Median Earnings – Youth will attain employment at an average 3-month salary of $4,000 no later than the second quarter after exit.

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By achieving these objectives, youth participants will secure stable employment, increase their earning potential, and create pathways for career advancement, leading to greater financial security and improved well-being. At the same time, the City of Santa Ana will benefit from a stronger workforce, reduced unemployment rates, and increased economic growth.

Target Population

Total Number of Youth to Be Served: Hope Builders will serve 20 youth through this project.

Age Range of Youth to Be Served: Hope Builders will serve youth between the ages of 18-24.

Minimum Requirements to Be Enrolled: Participants must be Out-of-School youth ages 18-24 and a resident of the City of Santa Ana (except for foster youth, emancipated youth, and wards of the court). Participants must demonstrate stable housing and pass a drug test prior to enrollment. Eligible youth include school dropouts, those with a secondary diploma or equivalent who are basic skills deficient or English language learners, youth in the juvenile or adult justice system (for CTP only), parenting youth, and individuals with disabilities.

Participants must demonstrate motivation and readiness (which includes obtaining a driver’s license and right-to-work documents). Youth who have already obtained a postsecondary degree will be ineligible to enroll.

Hope Builders encourages pregnant individuals to apply once they are ready to fully participate in training and employment. This ensures they can complete the program successfully and secure stable, long-term careers with the support and resources available.

Serving Foster Youth, Homeless Youth, & Youth on Probation: Hope Builders' programs are open to foster and emancipated youth, as well as wards of the court. Hope Builders does not enroll homeless youth; applicants must demonstrate stable housing before enrollment to avoid the challenges associated with homelessness, such as inconsistent attendance or difficulties focusing on training. Hope Builders also serves youth offenders through CTP, but participants cannot have an open court case at the time of their enrollment. Additionally, parolees must coordinate with their Parole Officer to ensure they can meet program requirements. Due to employer partner restrictions, youth offenders are not eligible to enroll in the CMA or CDC programs.

How Targeted Youth Populations Will Be Recruited: Hope Builders will recruit targeted populations through a variety of efforts. Outreach Specialists will actively market the program at local churches, community centers, and other youth-serving nonprofits. A significant portion of students (about 65%) will be referred by current or former participants. Additional referrals will come from community partners such as Learn4Life, Big Brothers Big Sisters, Centennial Education Center, La Familia, Youth Provider Network, and others. Hope Builders’ Outreach team will also hold regular office hours at partner locations like Project Kinship, Orangewood, and certain ACCESS schools, where they will meet with prospective applicants to discuss the EXHIBIT 3

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program and start the application process. In addition, advertising and social media campaigns will help raise awareness and generate over 10,000 “Applicant” page views quarterly on the organization's website.

Recruitment Plan: Recruitment will be ongoing, with efforts taking place on a weekly or monthly basis. Hope Builders will recruit youth through a variety of channels, including outreach at community centers, churches, jails, social service programs, and schools. Hope Builders' Outreach team will also maintain office hours at several community partner locations such as Big Brothers Big Sisters, Orange County Conservation Corps, and Phoenix House, among others. Social media campaigns will be used to increase awareness about the program. In the most recent quarter, Hope Builders’ social media efforts drove 5,349 website sessions, 66,011 total social media engagements, 78,664 organic video views, and 1,652 clicks to the applications page from both paid and organic campaigns.

Prospective trainees will complete an application form documenting their employment history, income, household size, and participation in social service programs. They will also take the TABE test to assess their basic skills levels (5th-8th grade). In addition, right-to-work documents, driver's licenses, school transcripts, and background screenings will be collected.

These materials will be reviewed and discussed, along with motivations and potential barriers during the applicant's interview to determine readiness. Once eligible, the youth will attend a one-week orientation at Hope Builders where they will meet staff, review program expectations, and commit to fulfilling them. Youth who are admitted into the program will be expected to demonstrate reliability by showing up every day, on time, drug-free, and with a good attitude.

Program Assessment

Required Assessment Tools: Hope Builders will use the required Test for Adult Basic Education (TABE) assessment.

Assessment Procedures for Youth Participants: During the admissions process, Hope Builders uses the TABE assessment to measure academic skills in areas such as reading, mathematics, and language. Additionally, the IRIS assessment is used to evaluate over 100 behavioral mindsets and essential skills, including basic and occupational skills, prior work experience, employability interests, aptitudes, and support service needs. The data from these assessments is used to create personalized service strategies for each participant. These strategies are linked to key performance indicators, identify career pathways that include education and employment goals, outline achievement objectives, and specify appropriate services. Hope Builders staff meet weekly to review each participant’s progress toward their individualized service strategy goals.

Understanding of Youth Participant Barriers: With an average household income of just $30,639, all 282 participants enrolled in the previous fiscal year met HUD’s low-income EXHIBIT 3

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threshold for Orange County. Of those, 89% were classified as extremely low-income, and 55% lived at or below the Federal Poverty Level guidelines. Of those served, 14% were parents, 15% had been involved in the justice system (limited to the construction pathway, as healthcare roles require clean backgrounds), 30% had experienced trauma specifically related to domestic violence or foster care emancipation, 60% were women, and 96% identified as Hispanic/Latino.

Consequently, many participants experience significant barriers that delay their progression toward self-sufficiency. These barriers include lack of childcare, transportation, family instability, unstable housing, food insecurity, abusive relationships, anger management issues, mental/emotional health challenges, substance abuse history, low self-esteem, criminal records, ongoing legal or court obligations, difficulty managing finances, and lack of computer literacy.

Addressing the Barriers Faced by Youth: Hope Builders addresses barriers faced by youth by offering personalized support through a structured process focused on improving employment readiness and life skills. The program helps trainees set concrete goals, such as completing a high school diploma, obtaining a valid driver's license, managing a bank account, setting up a professional email account, and avoiding unhealthy relationships, crime, and drugs. The process begins with an intake meeting, where an Employment Readiness Specialist/Coordinator builds rapport with each participant and identifies potential barriers. Using intake data and assessments, the specialist develops two key goals: an IRIS goal, based on the participant's assessment, and a Workforce Readiness goal, co-created with the trainee to address specific needs for employment preparedness. Additionally, the Employment Readiness Specialist/Coordinator leads weekly soft skills classes to help trainees develop essential workplace skills and holds one-on-one meetings to monitor progress. This holistic approach is designed to help youth overcome barriers and achieve long-term success in both employment and personal development.

Paid & Unpaid Work Experience

Paid & Unpaid Work Experience Opportunities: Hope Builders' CMA program includes a 160- hour externship designed to provide hands-on clinical experience essential for employment as a Medical Assistant. After successfully completing 16 weeks of training, trainees are matched with a clinical site for a four-week, unpaid externship. This opportunity allows participants to gain real-world experience, demonstrate their skills to potential employers, and prepare for job placement. Trainees are expected to maintain reliable attendance, adhere to workplace professionalism, and communicate regularly with both their employer and Hope Builders’ Employment Services team. Additionally, the program encourages trainees to take steps toward reliable transportation, such as obtaining a driver's license or creating a savings plan for future vehicle ownership. Throughout the externship, performance is evaluated based on employer feedback to ensure trainees are job-ready and equipped for long-term career success.

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Hope Builders does not offer paid work experience; it offers employment in career pathway jobs through its social enterprise staffing agency, Hope Builders Career Connections (HBCC). As an employer, HBCC places graduates of the CTP, CMA, and CDC programs and places them in full-time positions that provide a living wage and opportunities for career advancement. HBCC carefully vets job opportunities, facilitates placements, and offers ongoing support during the first six months of employment to ensure job retention and success. Graduates are placed in roles through either temp-to-hire opportunities, allowing employers to assess fit before making permanent offers, or direct placement into long-term positions. Through this structured approach, Hope Builders helps young professionals build stable careers with clear pathways for growth

Preparing Youth for Targeted In-Demand Industries: Hope Builders will support workforce development in the Healthcare industry through its CDC and CMA programs. These programs equip participants with the essential skills, training, and certifications needed to secure employment in high-demand healthcare roles. By aligning with employer needs and industry standards, Hope Builders ensures that graduates are prepared for sustainable careers in healthcare, addressing workforce shortages while providing young professionals with pathways to economic mobility.

Job Training & Preparation Through STEAM: Hope Builders integrates elements of STEAM (Science, Technology, Engineering, Arts, and Mathematics) into its job preparation training by providing basic skills remediation in math and reading, tailored to industry needs. Construction trainees develop math skills such as algebra, geometry, and trigonometry for estimating material costs and reading blueprints, while healthcare trainees focus on science and math concepts like medical vocabulary and dosage calculations. Up to two hours daily are dedicated to building these essential skills through worksheets, college-level books, lectures, and support from volunteer tutors.

Work Experience Opportunities Related to Postsecondary Certificate Programs: Hope Builders’ CMA program provides work experience opportunities through a 160-hour externship, which is a required component of the program. This hands-on experience allows trainees to apply their skills in a real-world clinical setting, ensuring they are job-ready upon completion. Graduates who successfully complete the program and externship receive a Vocational Medical Certificate of Completion (Non-Credit) in partnership with Santiago Community College.

Employers That Support Paid/Unpaid Work Experience: Hope Builders partners with approximately 10 healthcare businesses across Orange County to serve as host sites for CMA externships. These include Associated Gastroenterology Medical Group, Dr. Irene Pe, Lestonnac, Sunrise Healthcare Centers, Kindred Healthcare, Zhana Rapoport, MD, Centers of Rehabilitation & Pain Medicine, Reviv Functional Psychiatry, Beach Family Doctors Medical Group, and Jason Kurtz, DO.

Alternative Secondary School Services
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Alternative Secondary School Services: For youth who require alternative secondary school services, Hope Builders provides referrals to Learn4Life and the Orange County Department of Education (OCDE) for GED and High School Equivalency (HSE) support. These partnerships ensure that young people who have not completed high school have access to flexible, accredited programs that help them earn their diploma or equivalency. By connecting youth with these educational resources, Hope Builders supports their academic advancement and prepares them for workforce training and career opportunities.

Activities That Will Support Secondary School Diploma: Hope Builders supports youth in attaining their secondary school diplomas through a combination of academic assistance, mentorship, and holistic support services. Tutoring is available both before enrollment and during training to help applicants strengthen their academic skills. Personalized support and mentorship provide guidance from staff and mentors to keep students motivated and on track.

Additionally, case management and counseling offer one-on-one support to help students overcome academic and personal challenges, while goal-setting and career coaching assist them in planning their educational and career pathways. To further support students, Hope Builders provides social and emotional resources, including mental health services such as counseling and stress management.

Through these activities, Hope Builders ensures that youth have the necessary resources and support to complete their secondary education and successfully transition into career training and employment.

Preparation for Postsecondary Education and Training

Preparation for Postsecondary Education & Training: Hope Builders equips youth with the skills, knowledge, and support needed to succeed in postsecondary education and training for high- demand industries such as healthcare and construction. Medical assisting remains one of the top ten in-demand allied health professions in California, with more than 12,000 positions left unfilled each year, according to California Competes. Additionally, California’s Employment Development Department projects over 15,000 openings for paraprofessionals through 2028.

Through CDC, CMA, and CTP, Hope Builders trains youth for middle-skill positions that ensure long-term employability, economic mobility, and career advancement. These positions are in industries offering livable wages, with entry-level jobs in healthcare and construction typically paying at least $18.50 per hour (adjusted annually) or offering full-time employment with a minimum of 30 hours per week. By focusing on these key industries, Hope Builders ensures that its graduates are prepared for sustainable careers that provide opportunities for growth and job security.

Collaborations With Postsecondary Institutions: Hope Builders collaborates with postsecondary institutions to provide trainees with industry-recognized credentials that enhance their career EXHIBIT 3

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opportunities. The CTP program partners with Santa Ana College to support MC3 Certification for trainees. Additionally, the CMA program connects participants to Santiago Canyon College, where they earn a Vocational Medical Certificate of Completion. These partnerships ensure trainees receive both hands-on training and formal education, strengthening their career readiness.

Career Pathways for Youth to Obtain Occupations with Livable Wages: Hope Builders' CDC, CMA, and CTP programs provide clear pathways for career advancement in applied behavior analysis, healthcare, and construction. CDC graduates start as behavior technicians (BTs) and can advance to Board Certified Behavior Analysts (BCBAs), occupational therapists, or teachers by gaining experience, earning additional college units, and obtaining higher-level certifications.

CMA graduates begin as medical assistants (MAs) and can progress to roles such as licensed vocational nurses (LVNs), registered nurses (RNs), or healthcare administrators through further education and certifications. CTP graduates enter the construction field with foundational skills, with opportunities to become journeymen, foremen, site supervisors, or project managers through experience and additional training. By equipping youth with industry-recognized credentials, job placement support, and long-term career guidance, Hope Builders ensures that participants have access to stable employment with opportunities for professional growth and higher wages.

How Youth will be prepared for Postsecondary Education & Training: Hope Builders prepares youth for postsecondary education and training by offering a comprehensive, personalized approach that equips them with the essential skills needed for success in both technical instruction and hands-on learning. Trainees receive the support they need to develop academic and practical competencies, with a focus on building a strong foundation for success in their chosen industries, such as healthcare and construction.

In addition to academic readiness, Hope Builders places a strong emphasis on soft skills development, which is crucial for workforce success. Employment Readiness Specialists/ Coordinators work with trainees to enhance communication, problem-solving, teamwork, and time management skills. Through weekly meetings and workshops, Employment Readiness Specialists/Coordinators provide individualized guidance, helping trainees develop key soft skills such as accountability, initiative, and professionalism.

By combining academic support, soft skills development, and personalized case management, Hope Builders ensures that youth are well-prepared for both technical training and real-world applications, positioning them for success in high-demand industries and long-term job retention.

WIOA Recognized Certificates for Youth: Hope Builders provides youth with the opportunity to earn WIOA-recognized certificates during training or within one year after program completion, equipping them with industry-recognized credentials for career advancement.

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As previously noted, CMA trainees earn a Vocational Medical Certificate of Completion (non- credit) from Santiago Canyon College, American Heart Association BLS Certification, HIPAA and PPE Training Certificates, OSHA Certifications in Bloodborne Pathogens, Hazard Communication, Workplace Violence Prevention, and Hope Builders’ Certificate of Completion.

CDC Trainees earn a 40-Hour Behavior Technician Training Certificate, American Heart Association Heartsaver Pediatric First Aid & CPR Certification, California Mandated Reporter Certificate, and Hope Builders’ Certificate of Completion. CTP trainees earn MC3 Certification, Career Technical Education Certification through Santa Ana College, OSHA 10-Hour Certification, American Heart Association First Aid & CPR Certification, and Hope Builders’ Certificate of Completion.

The certifications listed above include a combination of credentials accredited by state- recognized educational institutions and those widely recognized by employers in their respective industries. These certifications equip Hope Builders graduates with the qualifications needed for employment, career advancement, and long-term success in high-demand fields.

Supporting Data & Research for Identified Industries/Pathways: Economic instability remains a significant challenge in Orange County, despite its reputation for affluence. According to Orange County United Way’s 2025 Real Cost Measure study, 311,862 households (34%) are low-income and struggle to meet basic living expenses, with highest rates among Hispanic/Latino (53%) households. Economic hardship is closely tied to education, with 71% of households without a high school diploma falling below the poverty line, compared to 20% of those with a college degree.

Workforce training and education are critical to breaking the cycle of poverty. The 2023 California Jobs First survey, conducted by the Orange County Business Council, found that education, training, and skills development programs are the most effective strategy for creating accessible jobs for economically disadvantaged individuals. In response, Orange County's High Road Transition Collaborative (HRTC) has prioritized workforce development in Healthcare & Social Assistance and Construction, two of the top five key industry sectors. By aligning its training programs with these high-demand industries, Hope Builders ensures that youth gain the skills and credentials needed for stable, well-paying careers, creating pathways to economic mobility.

Tutoring

Tutoring Resources & Academic Support for Youth: Hope Builders' service population typically tests between a 5th and 8th-grade level in math and reading, as measured by a pre-training TABE assessment. To help youth improve their basic skills, each training program integrates math and English remediation into the curriculum. Weekly tutoring is available to candidates upon submission of an application to the job training program. Once enrolled, participants engage in 2–3 hours of daily instruction tailored to their field—algebra and geometry for construction, dosage calculations and healthcare vocabulary for medical careers, as well as EXHIBIT 3

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business math and English. To assist youth struggling with the curriculum, volunteers provide weekly math and English tutoring. After successful completion of training, participants are expected to demonstrate at least a one-grade-level improvement in either math or English on their post-training TABE test, increasing their preparedness for and likelihood of success in the workforce.

Mentoring

Mentoring Opportunities for Youth: Hope Builders provides mentoring opportunities as part of its comprehensive approach to workforce development. Recognizing that skills training and job placement alone are not enough to support disconnected youth, Hope Builders integrates adult mentoring to help participants develop life skills and sustain long-term employment. Upon enrollment, each youth is paired with an Employment Readiness Specialist/Coordinator who provides guidance and helps them achieve tangible goals. Throughout the 6- to 24-week training program, Employment Readiness Specialists/Coordinators meet with participants weekly to monitor their progress. After training, staff supports graduates to ensure a smooth transition into the workforce until 6 months of employment retention is achieved. Hope Builders' holistic model is rooted in research and best practices in youth development, ensuring that participants receive the mentorship and support needed for long-term success.

Support Services for Youth Facing Significant Challenges: Hope Builders provides comprehensive support services to help youth facing significant challenges overcome barriers to employment and long-term stability. Many participants experience challenges such as economic hardship, involvement in the justice system, or lack of a high school diploma. To address these challenges, Hope Builders offers personalized case management, mental health counseling, and life skills training to ensure youth have the resources they need to succeed.

Each participant is assigned an Employment Readiness Specialist/Coordinator who works closely with them to set and achieve personal and professional goals. Employment Readiness Specialists/Coordinators provide bi-weekly check-ins, mentoring, and referrals to essential services such as GED programs, childcare assistance, and housing support. Additionally, Hope Builders offers financial literacy training, transportation assistance, and legal aid referrals to remove common barriers to employment. Through this holistic approach, Hope Builders ensures that youth not only receive job training but also build self-confidence, resilience, and stability, equipping them for self-sufficiency and long-term career success.

Mental Health Services & Referral Support: Hope Builders offers both mental health support services and referrals to external mental health agencies. Employment Readiness Specialists/Coordinators help trainees navigate social, emotional, and mental health barriers by encouraging them to connect with their natural support systems and external resources to improve their overall well-being and workforce readiness.

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interventions. They focus on developing trainees’ social and emotional skills, including self- awareness, social awareness, self-management, and healthy relationship-building. This is accomplished through weekly one-on-one meetings, soft skills workshops, and regular assessments to identify and address barriers.

Additionally, Hope Builders connects trainees to external mental health resources as needed, ensuring they have access to professional support that enhances their ability to succeed in both their personal and professional lives.

Comprehensive Guidance & Counseling for Substance Use Issues: Prior to enrollment, Hope Builders provides guidance and support regarding drug and alcohol use as part of the intake process. All prospective trainees are required to pass a drug test to ensure they are ready to fully engage in training. If a participant has a history of substance use, the Employment Readiness Specialist/Coordinator will set a recovery goal and provide ongoing support throughout the training. If further support is needed, referrals to community-based drug and alcohol counseling services are provided to help individuals address these challenges.

Throughout the training, Employment Readiness Specialists/Coordinators will provide ongoing guidance, emphasizing the importance of making healthy choices and staying focused on career readiness. This proactive approach ensures that youth receive the necessary support to overcome barriers related to drug and alcohol use.

Workshops

Financial Literacy/Budget Management: Hope Builders provides workshops on financial literacy and budget management to equip youth with essential money management skills. At the start of training, banking partners lead financial literacy sessions for each program cohort, covering topics such as opening and using a bank account, online banking, writing checks, and saving money. Later in the program, Employment Readiness Specialists/Coordinators facilitate budgeting workshops, teaching trainees how to create and manage a budget based on their income and expenses.

Entrepreneur Skills Training: Currently, Hope Builders does not offer Entrepreneur Skills Training. However, our focus remains on preparing youth for direct employment in in-demand industries such as healthcare and construction.

Labor Market Information: Employment Readiness Specialists/Coordinators provide weekly 1- hour employment readiness workshops to explore labor market information. This includes three lessons on careers and career planning, two lessons on job searching, one lesson on reviewing job applications, two lessons on understanding the hiring process, one lesson on navigating job websites and platforms, and one lesson on researching potential employers.

Family Planning: Hope Builders does not offer formal family planning workshops but provides support for trainees who need assistance with childcare planning to help them complete the EXHIBIT 3

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program. Additionally, each cohort participates in a workshop led by nonprofit partner Laura's House to help participants build and maintain positive relationships, make informed decisions, and resist peer pressure, all of which contribute to a stable foundation for career success.

Worker's Rights/Labor Laws: While Hope Builders does not currently offer dedicated workshops on Worker's Rights or Labor Laws, professionalism and responsible workplace behavior are reinforced throughout training. Trainees learn about workplace expectations, ethical practices, and their rights as employees. Additionally, OSHA training provides essential knowledge of workplace safety regulations, ensuring trainees understand the standards employers must uphold.

Analytical Skills at the Workplace: Hope Builders does not offer standalone workshops on analytical skills in the workplace; however, these skills are integrated into industry-specific training programs.

Health Resources: Although Hope Builders does not offer specific workshops on Health Resources, our Employment Readiness Specialists/Coordinators provide one-on-one assistance and guidance related to mental health and well-being. Youth are encouraged to utilize these resources to address any challenges they may face during their training and transition to employment.

Professional Communication Skills (verbal, written, physical): Throughout the training period, Employment Readiness Specialists/Coordinators conduct weekly 1-hour employment readiness workshops to develop professional communication skills. These include 14 lessons on interview skills, one mock interview, one lesson on resume writing, one lesson on written communication etiquette, one lesson on writing a resignation letter, and one lesson on effective communication and accountability.

Navigating the Workplace: Employment Readiness Specialists/Coordinators conduct weekly 1- hour employment workshops on workplace navigation, covering key topics such as performance management (1 lesson), workplace communication and code-switching (1 lesson), workplace development through the "Sole Survivor" activity (1 lesson), and the process of resigning from a job (2 lessons).

Civic Engagement & Leadership Development

Civic Engagement & Leadership Development Opportunities: Hope Builders provides education on voter registration. Additionally, the organization incorporates limited leadership development within its "Workforce Readiness" framework, which focuses on key soft skills such as Accountability, Initiative, Attendance, Productivity, Cooperation, and Grit. Employment Readiness Specialists/Coordinators meet bi-weekly with youth to assess and support their growth in these areas, which are critical for a successful transition into the workforce. As part of EXHIBIT 3

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this process, each trainee is required to participate in at least one outreach or volunteer event, helping them develop leadership skills while contributing to their community.

Number of Youth in Civic Engagement & Leadership Development: All 20 youth who will be supported through this program will participate in the leadership development activities provided above.

Supportive Services

Hope Builders provides supportive services to youth enrolled in our training programs to help address financial hardships and barriers to participation.

Transportation Assistance: Bus passes and gas cards are available to trainees during the training phase and, in rare or emergency situations, may also be provided during the placement phase.

To qualify, trainees must demonstrate financial hardship. Employment Readiness Specialists/Coordinators work with trainees to create a budget plan, offering financial guidance alongside this support. Bus passes may be distributed at the start of training at the discretion of the Employment Readiness Specialist/Coordinator, with proper documentation and approval from the Employment Readiness Manager. For trainees without a driver's license, Hope Builders partners with GNC Driving School to provide behind-the-wheel instruction as needed, including six hours of training, one hour of supervised practice before the test, and the use of a vehicle for the exam.

Childcare Assistance: Hope Builders offers childcare stipends to active trainees in the training phase. “Childcare” is broadly defined and includes traditional childcare facilities, babysitting by family or neighbors, and essential child-related expenses such as diapers, formula, food, and clothing. This assistance is intended to support trainees in attending classes, externships, and achieving their program goals.

Emergency/Special Funds: Limited emergency funding may be provided to trainees facing financial hardships that could impede their ability to complete training or secure employment.

This may include one-time assistance for essential expenses, such as a utility bill or fees for a DMV permit test.

These supportive services are designed to ensure trainees can fully participate in their training and successfully transition to employment.

Supportive Service Policy: Please see Attachment N for Hope Builders' supportive service policy.

Incentives

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Incentives for Youth Achievement & Goal Attainment: Hope Builders offers training stipends of $100 per week ($20 per day) to program participants. During the first 6-24 weeks of training, Employment Readiness Specialists/Coordinators meet bi-weekly with trainees to monitor their progress and set goals with actionable steps. The stipends are designed to maintain engagement during the training period and encourage participants to take proactive steps toward their career and educational goals. Stipend amounts are at the discretion of the Training Supervisor and may be reduced based on attendance and cooperation. At program completion, Employment Readiness Specialists/Coordinators (alongside the entire training team) conduct end-of-training assessments to ensure that participants are ready to enter the workforce or a post-secondary program.

Follow-Up Services

Services Provided During the 12-Month Follow-Up Period: After exit, Hope Builders will provide employment placement support, case management support, and quarterly check-ins after.

Case Management, Job Retention, & Mentoring to Support Goal Attainment: Throughout the 12-month follow-up period, a Grant Administrator will conduct quarterly check-ins to track employment status, provide additional resources, and ensure youth remain on a path toward long-term career success. Hope Builders will also provide 12 months of support to program graduates through its HBCC staffing agency to help them secure employment and ensure a smooth transition into the workforce. To promote job retention and career success, graduates may receive case management support up to twice a week for six weeks after program completion. This will include addressing workplace challenges, connecting participants to resources, and providing guidance to help them stay employed and achieve their career goals.

Ensuring Youth Meet Performance Indicators During Follow-Up: During the follow-up period, Hope Builders will ensure that youth meet the Performance Indicators through regular case management, support, and goal tracking. A Grant Administrator will conduct follow-up with program graduates in the 1st, 2nd, 3rd, and 4th quarters after exit to monitor progress.

Additionally, case management services are provided up to 6 weeks after exit, offering guidance on job retention, career advancement, and overcoming barriers. These efforts ensure that youth stay on track to meet their performance goals.

Incentives & Supportive Services to Enhance Youth Retention: Program graduates do not receive additional incentives after graduation, as they are expected to earn income from their employment. Supportive services, including case management and follow-up assessments, are available as previously described to assist with job retention and career advancement.

Frequency of Youth Engagement & Services During Follow-Up: As noted, HBCC will provide up to 12 months of employment placement support. During the follow-up period, program graduates may receive case management support up to twice a week for the first six weeks after program completion. Additionally, a Grant Administrator will conduct quarterly check-ins EXHIBIT 3

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to track employment status, provide additional resources, and ensure youth remain on a path toward long-term career success.

WIOA Performance Indicators

Percent of participants who are in education or training or unsubsidized employment during the 2nd quarter after exit.

Anticipated
Outcome
Strategies Measures
Youth will attain
employment
and/or enter post-
secondary
education.

Hope Builders will provide job
placement assistance through its
HBCC staffing agency and
maintain employer partnerships
to connect youth with job
opportunities. Case management
and career coaching will help
participants navigate the
transition to employment or
further education.

At least 68% of youth will attain
employment or enter post-
secondary education, no later
than the second quarter after
exit.

Percent of participants who are in education or training or unsubsidized employment during the 4th quarter after exit.

Anticipated
Outcome
Strategies Measures
Youth will attain
employment
and/or enter post-
secondary
education.

Ongoing follow-up services,
including quarterly check-ins and
additional job search support, will
ensure youth remain employed
or enrolled in post-secondary
education. Retention strategies
include mentorship, professional
development workshops, and
access to community resources.

At least 62% of youth will attain
employment or enter post-
secondary education, no later
than the fourth quarter after exit.

Document the median earnings of participants in unsubsidized employment during the 2nd quarter after exit.

Anticipated
Outcome
Strategies Measures
Youth will attain
earnings above
minimum wage.

Hope Builders will document the
median earnings of participants
through follow-up surveys and
direct communication with
Youth will attain employment at
an average 3-month salary of
$0,000 no later than the second
quarter after exit.

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employed graduates. For non-
responsive participants, Hope
Builders will obtain employment
data through the Work Number.

All collected data will be recorded
in Social Solution's Apricot
software.

Percent of participants who obtain recognized postsecondary credential or secondary diploma during participation or within 1 year after exit.

Anticipated
Outcome
Strategies Measures
Attain a Credential/
Diploma/Certificate
Training programs will
incorporate industry-recognized
certifications and provide
structured support, including
tutoring, study groups, and test
preparation, to ensure
participants successfully
complete certification
requirements.

At least 62% of youth will attain a
Credential/Diploma/Certificate
within 1 year after exit.

Percent of participants who, during the program, are in education or training that leads to a recognized postsecondary credential or employment AND who are achieving measurable skills gains.

Anticipated
Outcome
Strategies Measures
Youth attain a
recognized post-
secondary
credential through
training and
increase their basic
skills levels.

Hope Builders provides industry-
recognized certifications through
its CDC, CTP, and CMA programs.

CDC participants can earn
certifications such as the RBT
Examination, Behavior Technician
40-Hour Training, and Pediatric
First Aid & CPR, preparing them
for careers in early childhood
education and behavioral
therapy. CTP trainees obtain MC3
Certification, Career Technical
Certification, and OSHA 10-Hour
Certification, equipping them
with essential construction skills.

CMA participants earn the
At least 59% of youth will attain a
recognized post-secondary
credential through training AND
achieve measurable skills gains.

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Vocational Medical Certificate of
Completion from Santiago
Canyon College, along with
certifications in BLS, HIPAA, and
OSHA safety standards for
healthcare.

To further support credential
attainment, Hope Builders
integrates basic skills remediation
in reading and math, ensuring
trainees meet academic
requirements for certification.

Additionally, all participants
receive employment readiness
training, including interview skills,
resume writing, workplace
communication, teamwork, and
leadership, ensuring they are fully
prepared to enter the workforce
and advance in their chosen
careers.

Effectiveness in serving employers.

Anticipated
Outcome
Strategies Measures
Employers report
satisfaction with
program graduates.

Hope Builders will foster strong
employer relationships by
maintaining regular
communication, providing job-
ready candidates, and offering
post-placement support.

Employers will receive structured
evaluation surveys to assess
participant performance in
technical skills, initiative, and
professionalism. Feedback will be
reviewed to improve training
programs and ensure graduates
meet employer expectations.

Pending further State and Federal
Guidance.

Prior Outcomes
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Performance Outcomes (Santa Ana WDB Grant)
2023 (Example 5 ÷ 15 = 33%) 2024 (Example 5 ÷ 15 = 33%) Measurable Skill Gain n/a n/a
Entered Employment or
Post Secondary
n/a n/a
Attained
Credential/Diploma/
Certificate
n/a n/a

Performance Outcomes (Other OC WDB Grant)
2023 2024
Measurable Skill Gain 86% 96%
Entered Employment or
Post Secondary
93% (4th Quarter after exit) 73% (4th Quarter after exit) Attained
Credential/Diploma/
Certificate
100% 73%

Fiscal Competency

Process for Capturing & Reporting Fiscal Data: Hope Builders captures and reports fiscal data using QuickBooks Enterprise, which records all income and expenses. The data is tracked on an accrual basis of accounting to ensure accuracy and compliance with federal requirements. The agency develops accounting and administrative measures to manage fiscal records, including tracking all income, expenses, and grants. Monthly financial statements are prepared by staff and reviewed by the Executive Director. Additionally, an annual independent audit is conducted to ensure financial integrity and compliance.

Systems for Fiscal Accountability & Cost Management: Hope Builders ensures fiscal accountability through a well-established internal control system. The agency uses an annual budget, approved by the Board of Directors, to plan expenditures and costs. Financial data is tracked by account and grant in the general ledger, ensuring proper documentation and management of funds. The Finance Committee, Department Managers, and Board of Directors conduct bi-monthly reviews of financial statements to monitor expenditures and ensure alignment with the budget. A procurement policy is in place to guide expenditure decisions and ensure costs are appropriate and in compliance with planned budgets.

Invoicing Process & Staff Qualifications: Hope Builders generates quarterly invoices for services provided, ensuring that all costs are appropriately documented and aligned with grant requirements. Invoices and cost reports are reviewed by the Controller, who is responsible for verifying the accuracy of these reports and ensuring compliance with the budget. The EXHIBIT 3

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Controller holds a BS in Accounting and has significant experience working with small businesses, particularly non-profit organizations. This ensures that the invoicing process is accurate and aligns with fiscal policies.

Financial Stability & Independence from WIOA Funds: Hope Builders' financial stability is not solely reliant on WIOA funds due to its diversified revenue streams. While WIOA funds contribute to the budget, they represent only a portion of the overall funding. As previously noted, the organization generates revenue from multiple sources, including $1,825,000 from individual contributions, $1,420,000 from grants, $630,000 from program service revenue, and $601,487 from Hope Builders Career Connections (HBCC), the organization’s social enterprise staffing agency (net of labor costs). This diversity in funding ensures that the organization remains financially stable, even in the absence of fluctuations in WIOA funding.

Budget Allocation (Direct Youth Support vs. Administrative Costs): 82.5% of the budget will go directly to youth in the form of work experience payments, direct training, supportive services, and other related expenses. The remaining 17.5% will be allocated to administrative costs, primarily to fund the Grants Administrator and Director or Programs positions.

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WORK EXPERIENCE POLICY
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EXTERNSHIP

In order to obtain employment as a Medical Assistant need to complete 160 hours of hands-on work experience in the field. After you successful completed the first 16 weeks of training, Hope Builders will match you with a clinical site where you will complete a 4-week, 160-hour externship. This externship is unpaid, and you will not receive a stipend during this time. This is your chance to impress the employer and show them you’re ready to work. Here’s some of what you’ll need to do:

Grow your Work Experience Complete 160-hours of clinical experience over 4- weeks
• Turn in your weekly time report through an
approved
method
• Communicate with the Employment Services team
at
Hope Builders at least weekly
Maintain Reliable Attendance • Be on-time
• Come to work every day as scheduled
• Communicate with your employer ahead of time
Take the next step to ensure
Reliable Transportation
If you received your permit in the first 12 weeks, get a driver’s license.

If you have your driver’s license, work with Hope
Builders to set up a savings plan to own your own
vehicle some day!

During your externship, we will rely on feedback from your Field Supervisor at your assigned job site to evaluate you. The goal is to ensure you have the skills and experience to prepare you for employment and job placement.

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STIPEND POLICY
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Trainee Handbook revised 10/2023 28

HOPE BUILDERS STIPEND ACKNOWLEDGEMENT

Stipend Policy
Applicants that become active trainees and are enrolled in the training program are eligible to earn a $100.00 weekly stipend that is paid bi-weekly.

If a trainee is d ismissed or withdrawn from the training program, that trainee’s final stipend amount will be prorated depending on the number of days active in the pay period. All borrowed materials, such as laptop, laptop charger, laptop case, textbooks, tools/supplies, etc., need to be returned to Hope Builders the same day they are dismissed or withdrawn. The final payment (and any other regular stipends) will be placed on hold until the train ee returns all HB property. The trainee will forfeit their remaining stipend if HB property is not returned.

• Stipends are issued bi-weekly according to the Stipend Calendar Schedule o Payments are disbursed via Skylight One Prepaid Mastercard • Stipend amounts are at the discretion of the Training Supervisor and may be reduced based on attendance and cooperation. Any full day of absence will result in the loss of a day’s pay ($20 per day).
• Stipends and other student assistance payments are considered earned income and may be taxable by the Federal and State government.
o Hope Builders may issue and mail a 1099 misc. tax form for IRS reporting at the end of the calendar year.
o Notify Accounting & Admissions dept. if there is a mailing address update for one year after the dismissal/withdrawal/ or training end date. • Prior to receiving a stipend, individuals must fill out the I -9 employment authorization form and provide required documentation.

Acknowledgements
• I read and understand the Hope Builders Stipend Policy. • My signature indicates I will comply with the Hope Builders stipend policy.

Print Name Date

Signature

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SUPPORT SERVICE POLICY
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1 Standard Operating
Procedures

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2 Table of Contents

Introduction ……………………………………………………………………….…………………………....................................................... 3 Pronoun Usage and Preferred Names ……………………………………………………………………………………………………………….. 3 SOP Change Language ……………………………………………………………………...………………………………………………………….….… 4 Support Services ………………………………………………………………………………………..……………………………………………………... 5 Pre-Orientation ……………………………………………………………………...…………………………………………………………………..…… 12 Orientation ……………………………………………………………………...……………………………………………………………………………... 13 Training ……………………………………………………………………...………………………………………………………………………………..…. 15 End of Training/Career Builder ……………………………………………………………………...……………………………………………..…. 23 Other Duties ……………………………………………………………………...………………………………………………………………………….... 24

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3 INTRODUCTION

This handbook outlines the guidelines, requirements, and procedures for the work performed by Support Specialists at Hope Builders. It aims to provide direction about how to conduct services from intake through program completion and ensure common procedures, which must be followed in their entirety.

PRONOUN USAGE AND PREFERRED NAMES
Purpose: This SOP establishes guidelines for the respectful and inclusive use of preferred pronouns and names at Hope Builders. Our commitment to diversity, equity, and inclusion ensures that all individuals feel acknowledged and valued.

Scope: This policy applies to all employees, contractors, volunteers, and any representatives of Hope Builders.

Policy Statement: All individuals at Hope Builders are entitled to be addressed by their preferred pronouns and names. Respecting gender identities fosters a positive and inclusive workplace culture.

Guidelines:

1. Ask for and Use Preferred Pronouns:
o When meeting new individuals, politely inquire about their preferred pronouns using phrases like:
▪ "What pronouns do you use?"
▪ "How would you like to be addressed?"
o Avoid making assumptions about a person's gender identity. o Respectfully use the pronouns and names provided in all interactions. o Enter the preferred name in Apricot.
o Enter the legal name on all legal documents, including attendance logs, certificates, and CPR cards.
o On non-legal documents, the preferred name will be included within parentheses between the First and Last legal names. For example: Madeline (Matt) Baker

2. Respect Preferred Names:
o Always refer to individuals by the name they provide as their preference. o If an individual includes a preferred name, use the preferred name in day-to-day conversations.
o Update communication records and directories to reflect preferred names, if applicable.

3. Correction and Apology:

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4 o If a mistake is made in pronoun or name usage, promptly acknowledge and correct the error.
o Offer a brief and sincere apology if appropriate and continue the conversation respectfully.
o Avoid prolonged apologies that may draw undue attention.

4. Educational Resources:
o Hope builders will provide training and resources to promote understanding of gender identity, inclusive language, and respectful communication.
o Encourage employees to participate in these learning opportunities. o Trainees will be provided training in Orientation.

5. Privacy and Confidentiality:
o Treat all information regarding an individual's gender identity, pronouns, and preferred name with strict confidentiality.
o Do not disclose this information without explicit consent. o Ensure that internal systems and records are updated to reflect the individual's preferences while maintaining privacy.

Enforcement: Failure to adhere to this policy may result in corrective action, in accordance with Hope Builder’s disciplinary procedures.

Review and Updates: This SOP will be reviewed annually and updated as needed to reflect best practices in inclusivity and respectful communication.

Contact: For questions or additional resources, contact Human Resources and/or the Director of Programs.

By following this policy, we contribute to a respectful and welcoming environment for all members of our community.

SOP Change Language
Trainees who have not achieved Demonstrating Progress or better by the half-way point of the cohort (week 6 on 12-week cohort trackers or week 8 of 16-week cohort trackers) will be exited for CMA and CTP.

o This should be communicated as a policy to prospective trainees at a minimum in Admissions, Week 1 of training, and during Week 4 Progress Reports. o WR Readiness Facilitators will trigger DOP to be present for the mid-point WR Meeting to discuss dismissals as a WR Triangle.
o Note: trainees who have demonstrated a pattern of WR progress, but who temporarily moved into Needs Improvement week 6 or 8 due to a PC can remain in the program.

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5 SUPPORT SERVICES
The purpose of the Support Services (Employment Readiness) team is to facilitate the success of trainees through resources and a safe environment to address barriers, enhance social emotional and soft skills to assist in collaboration with their workforce readiness team in meeting program outcomes.

Support Services refer to services and activities provided and conducted by Hope Builder’s Employment Readiness Specialists/Coordinators.

Hope Builders Support Services model takes an intentional case management approach using a biopsychosocial framework to understand the needs of trainees. This approach recognizes that trainees face barriers that are beyond issues of access.

Employment Readiness Specialists/Coordinators are equipped to help trainees address social, emotional, and mental health barriers and encourage the participant to connect with their natural supports systems and external resources to improve workforce preparedness. Support Specialists have differing levels of education and training, but all understand the role systems, the environment and trauma impact the lives of Hope Builders trainees and use the strengths of the individual and social and emotional skill building to enhance their lives.

Employment Readiness Specialists/Coordinators use a biopsychosocial framework that integrates personal involvement and various interventions to improve a trainees social and emotional skills and address their personal and environmental challenges to improve their workforce preparedness while maximizing a trainee’s strengths. To achieve this, Employment Readiness Specialists/Coordinators conduct the following activities:

▪ Comprehensive case management services with emphasis on social and emotional skill sets: self-awareness, social awareness, self-management, and healthy relationships (Done through 1:1 encounters and soft skills workshops) ▪ 1:1 weekly meeting’s
▪ Weekly Soft Skills classes
▪ Linkages to external resources
▪ Assess for barriers
▪ Collaborate with the trainee and/or with colleagues

Participant Stipends (Work Experience/WEX)
Participant stipends are provided to participants engaged in structured Work Experience (WEX) activities as part of program participation. Participants receive a $100 weekly stipend tied to documented participation hours in approved work-based learning placements and related program activities. These stipends support consistent engagement in training, reduce financial barriers to program completion, and are issued in accordance with established eligibility, approval, and documentation procedures. All stipend payments are tracked through required internal systems to ensure compliance with program and fiscal requirements.

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6 Program Materials, Supplies, and Stipends
Supportive Services at Hope Builders include essential materials, equipment, certifications, and program supplies required for participants in the CMA, CDC, and CTP programs to fully engage in training and successfully complete program requirements. These supports ensure equitable access to instruction and hands-on learning across all training pathways.

Program supplies include industry-specific textbooks, workbooks, tools, uniforms, safety equipment, and certification-related materials required for training and credential attainment.

Additional classroom and learning supplies such as notebooks, binders, writing materials, calculators, and organizational tools are also provided to support participant engagement and skill development throughout the program.

Supportive Services also include certification and testing/exam fees required for credential attainment, in addition to required training materials.

Supportive Services further include transportation assistance (including bus passes and gas cards) and childcare assistance provided to reduce barriers to participation in approved program activities, in accordance with established program procedures.

Supportive Services also include required drug testing and background checks to meet program, training site, and employer eligibility requirements. These services are provided in accordance with established program procedures and are documented and tracked as part of participant onboarding and compliance requirements.

Supportive Services described above are aligned with and implemented through the corresponding detailed procedures outlined in the Transportation Assistance and Childcare Stipend sections of this policy.

Gas Cards and Bus Passes
Bus passes and gas cards are available to Hope Builders trainees in training phase only and in very special circumstances or emergencies to trainees in placement phase. To be eligible, trainees must be enrolled in a Hope Builders training program and present with a financial hardship. Upon providing a gas card or bus pass the Employment Readiness Specialist/Coordinator should review the budget previously created with trainee (budgeting sheets/handouts located in Employment Readiness Teams folder). In some circumstances, a bus pass may be distributed to a trainee at the start of training at the discretion of the trainee’s Support Specialist. Staff should request bus pass from Employment Readiness Manager and must complete the bus pass log located in the Employment Readiness Teams folder, in addition to completing the 1:1 Case note in Apricot. See below for restrictions/limitations per Accounting Department. Gas cards and bus passes will be provided using non-WIOA funds.

RESTRICTION: Only the Finance Department is allowed to purchase gas/gift cards and bus passes.

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7 LIMITATION: All gift cards are considered as cash equivalents. Only hand out if the trainee is in need of the supportive service during training.

Gift Card Log: Each Employment Readiness Specialist/Coordinator issuing any type of gift card, gas card, bus pass to a trainee must complete the Card Log and enter a case note in Apricot. (The finance department uses the log and case note to expense the gift card appropriately in QuickBooks and for internal controls.) The Employment Readiness Manager is responsible for ensuring timeliness and accuracy of the Card Log and Case Notes are entered by the Employment Readiness Specialist/Coordinator.

➢ Fill out the log.
▪ Date Issued to Trainee
▪ Trainee Name
▪ Program/Cohort #

➢ Enter an apricot case note (this is useful for grant reimbursements) ▪ Select the type of service provided.
▪ Enter Amount
▪ Upload a copy of the card and the signature of the recipient on the case note.

Requesting More Gas/Gift Cards and Bus Passes:
▪ The Employment Readiness Specialist/Coordinator will submit a request via email for additional gas cards to the Employment Readiness Manager. ▪ It is recommended that the Employment Readiness Specialist/Coordinator request additional gas cards when there are 2 left in their possession. Bus passes should be requested on as needed basis (due to expiration date) Allow 2-week lead-time to process orders.

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8 Per the Finance Department:
▪ The Employment Readiness Manager is the only authoritative body to submit requests for more cards.
▪ The purchase of all cards may be delayed if the gift card log and case note & supporting document have not been completed by the Employment Readiness Specialist/Coordinator.

Distribution of Cards to the Employment Readiness Specialist/Coordinator:
▪ Requested cards will be hand delivered to each Employment Readiness Specialist/Coordinator.
▪ Upon delivery, the Employment Readiness Specialist/Coordinator must sign a “received receipt” to receive gift cards. Delivery will be rescheduled if the Support Specialist is unavailable.
▪ Received receipt will be kept for accounting records (Name, date, signature) ▪ Azucena will upload backups to the folder in Teams labeled “STAFF_Gift Cards Copies 2023.”
o Rename the file as follows, Date given_Card Name_ Employment Readiness Specialist/Coordinator first & last name_# of cards given (easier access) o 2023.02.28_Shell Gas Card_Jane Doe_(7)

Distribution to Trainees:

The Employment Readiness Specialist/Coordinator will provide trainees with a gas card/gift card, or bus passes upon eligibility, based on financial need.

Transportation assistance is generally limited to one bus pass per month or up to two gas cards per month during the training phase, based on documented participation and financial need. Additional assistance outside of these limits may only be provided in special circumstances or emergencies with approval from the Employment Readiness Manager and appropriate documentation in Apricot.

The Employment Readiness Specialist/Coordinator will make a copy of the gas card/ buss pass with a trainee signature of receipt and date given. The trainee must also acknowledge receipt by signing a receipt form confirming the item was received, the date issued, and the value/type of support provided.
▪ The Employment Readiness Specialist/Coordinator will enter a case note in Apricot and upload the signed copy.
▪ The Employment Readiness Specialist/Coordinator will upload backups to the folder in Teams labeled “TRAINEE_Gift Cards Copies 2022-2023.”
▪ Rename the file as follows, trainee’s first & last name_Card Name_Date given (easier access)
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9 ▪ Jane Doe_Shell Gas Card_2023.02.28
▪ The Employment Readiness Specialist/Coordinator will also retain and upload receipts or equivalent proof of issuance (e.g., activation receipt, purchase record, or distribution log) for all gas cards and gift cards to ensure proper tracking, audit compliance, and verification of allowable supportive service expenditures.

Childcare Stipends
Childcare stipends are available to active trainees in the training phase at Hope Builders. The word "childcare" is a broad term and not limited to a childcare facility but includes babysitting by family, neighbors, etc. for the purpose of allowing trainees to attend classes, externship, study, and advance goals and action items established as part of their participation at Hope Builders. Childcare support is defined as payment for caregiving services that allow a participant to attend approved program activities such as training, externship, or study time.

This may include care provided by licensed childcare providers or informal caregivers (e.g., family members or neighbors), provided that the care is documented and approved according to program procedures.

Childcare support is limited strictly to documented caregiving services provided during approved program participation hours. It does not include reimbursement for any child-related personal expenses.

Requirements:
✓ Employment Readiness Specialist/Coordinator will determine that trainee is eligible for childcare assistance.
✓ Trainee must complete an application and provide dependent verification documentation, verify dependent lives with or has shared custody of them. ✓ Trainee application is approved by the Support Specialist Manager.

Application Process:
▪ Employment Readiness Specialist/Coordinator will provide trainees requesting childcare stipend assistance with a Childcare Application to be completed. ▪ Trainees will provide verification of child by showing SS card or birth certificate. ▪ Dependent must live with trainee or have some shared custody with trainee to qualify for the stipend.
▪ Employment Readiness Specialist/Coordinator will email completed applications to Employment Readiness Manager that they are ready for review for approval.

Employment Readiness Manager will review for approval.

Stipend Amounts:

Childcare support is reimbursed only for actual, documented childcare services or costs incurred by the trainee in order to participate in approved program activities.

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10 Reimbursement is based on verified expenses and is not provided as a flat monthly payment per child or household-based allowance.

Trainees who receive childcare assistance from an outside agency, such as Social Services, CALWORKS or others, may be eligible to receive a stipend from Hope Builders if the amount they receive from the outside provider does not fully cover their expenses. In this case, the Support Specialist must determine:

1. The trainee’s childcare expense.

2. The amount of assistance the trainee receives from the outside agency.

3. Calculate the trainee’s eligible childcare stipend amount.

In some cases, trainees may be granted less than the eligible amount through Hope Builders. For example, a trainee who has two children may report she receives $250 in monetary assistance from CALWORKS but pays $300 per month in childcare. If this is the case, this trainee would only be eligible for $50 monthly from Hope Builders.

Prorating Stipend Amounts:

Use the excel file: Childcare Stipend Prorate Template to calculate any prorated amounts for the beginning of training or the end of training.

1. If active trainees complete the training program and move on to the next phase prior to the month-end, issue a prorated check request stipend from the beginning of the final month to the end of training.

2. All active trainees will not receive their normal monthly childcare stipend during the office closure between December 25th through January 1st or its observed holidays.

Stipend amounts will need to be prorated during the month of December. (Prorated dates: 12/1 to 12/24 or 23rd if the 24th is an observed holiday)

3. If a trainee is dismissed or withdraws from the training program, the trainee is not eligible to receive the stipend.

Submitting Childcare Stipend Roster Requests:

It is the responsibility of the Employment Readiness Specialist/Coordinator to submit signed childcare stipend rosters to the SSM by the 23rd of each month (see procedure for submitting below). The SSM will email signed rosters to accounting via email at [email protected] within 24 hours.
o During the holiday season, due dates for submitting check requests will vary depending on office closure days.
o Accounting will issue payment at the beginning of the following month. o The Support Specialist must complete the 1:1 Case note Form, Stipend/Voucher section in Apricot.

• If a trainee is dismissed or leaves training phase prior to completing an entire month, the trainee is not eligible to receive the stipend. If a trainee moves on to the EXHIBIT 3

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11 placement phase of the program prior to completing an entire month, the stipend must be prorated for the time the trainee was in training.

Childcare Stipend Roster Procedure:

Child Care Stipend Roster form is located in the Employment Readiness Teams Folder.

1. Only use this new version of the Childcare Stipend Roster as this is a MACRO enabled file. (Previous files will not work in this new process. Transfer data from other files to this version and delete any previous version of the childcare stipend roster form.)

2. Update the Child Care Roster as normal. When ready, please send a link to the file to your manager, Ruth, for her review and approval.
a. To copy the link the file, follow these steps.
i. Click Share at the Top Right corner.
ii. Click Copy Link
iii.
iv. Send Employment Readiness Manager a message stating the Child Care Stipend Roster is ready for your review/approval/signature. Here is the link: Master Child Care Stipend Roster Form_CMA-24.xlsm (For example)
v. Upon approval Employment Readiness Manager will sign and inform Employment Readiness Specialist/Coordinator that Childcare Stipend has been approved/signed.

3. Once the roster is signed by both Employment Readiness Specialist/Coordinator and Employment Readiness Manager, Employment Readiness Specialist/Coordinator will Save the file as a PDF using the MACRO enabled version only available on the Desktop App and email PDF to Employment Readiness Manager. a. Select Editing on the Top Right corner.
b. Select Open In Desktop App
i.
c. Enable Content and Enable Macros if the file is asking for permission.

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12 d. When the file is ready to save as a PDF, select the icon “CLICK HERE TO SAVE TO PDF”
i. Each file will be saved in the cohort folder linked Step #1. ii. Contact briteCITY if you are having issues.
iii. Email the signed PDF version to SSM.

4. Employment Readiness Manager will send ALL Employment Readiness Specialist/Coordinators’ rosters to [email protected] for processing.

Feel free to reach out to briteCITY at [email protected], if you need the following assistance:
• SYNC teams/SharePoint to your file explorer and how to use them. o Attached are PDF instructions on how to SYNC the HB Program team. • How to use MACRO excel files.
• Need assistance signing PDF forms on your laptop.

PRE-ORIENTATION
Handoff Meeting
The week before Orientation, the Admissions team will conduct a “Handoff Meeting” where they inform the Employment Readiness Team about the applicants attending Orientation. This is an opportunity to learn more about your future trainees, the barriers that they may have, and the support that the team may need to provide during training. The Admissions team will schedule the meeting, coordinating a time that works best for both teams.

Prior to Orientation
Email Admissions Manager and CC Support Services Manager your Intake Schedule. This email should be sent 1-2 weeks prior to Orientation.

ORIENTATION

Orientation Responsibilities
Employment Readiness Specialists/Coordinators are responsible for completing the following with trainees during orientation week:
❖ Presentation: Intro to Support Services. The purpose of this presentation is to provide trainees with an overview of the support services provided during training. This presentation should be conducted by the Support Specialist assigned to work with the trainees for that cohort or covering for the cohort. The Admissions team will schedule a time for Support Specialist to present this topic during Orientation week.

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13 o PowerPoint will be available on Schoology and on Teams (SS Channel and Orientation Channel).

❖ Presentation: Time Management and Study Habits. The purpose of this presentation is to provide trainees with the tools needed to be successful in the training program by managing their time efficiently. This presentation should be conducted by the Support Specialist assigned to work with the trainees for that cohort or covering for the cohort.

The Admissions team will schedule a time for Support Specialist to present this topic during Orientation week.
o PowerPoint will be available on Schoology and on Teams (SS Channel and Orientation Channel).

❖ Orientation Kick-off/ Team Building Activity: This is done with your team to help build comradery amongst the cohort. Together, introduce yourself to the trainees and execute an icebreaker to help everyone get to know one another.

❖ Grade Orientation Assignment: Every staff member presenting during Orientation will be responsible for grading the Orientation assignment associated with their presentations. The following assignments will need grading in the “Orientation” course on Schoology. Please ensure that these items are graded the following morning/as soon as possible to ensure that Admissions acts in live time if action needs to be taken.

• Note: Employment Readiness Specialist/Coordinator will grade the Time Management & Study Habits assignment. There is no assignment for Intro to Support Services presentation.

➢ Prior to Intakes:
✓ Prior to the Intake Meeting, review each trainee’s application, interview notes and information provided by Admissions to identify potential challenges and barriers. ✓ Review each trainee IRIS assessment survey, to identify IRIS goal.

➢ Communication with Admissions
Please communicate with the Admissions team and your Employment Readiness Manager in live time throughout Orientation if any behavioral or concerning issues arise with trainees. This could include performance-based behaviors, tardy, lack of participation, falling asleep, individuals on cell phone, etc. When these issues arise, it is critical that admissions speak with the trainees promptly, provide opportunity to course correct, or if needed, dismiss the individual.

Please note: In the event there is more than one Employment Readiness Specialist/Coordinator assigned to a cohort, the Employment Readiness Manager will assign trainees to each Employment Readiness Specialist/Coordinator based on the best fit.

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14 Conduct Intakes
An “intake” is the first meeting with each participant and allows Employment Readiness Specialist/Coordinator to build rapport and identify possible barriers. Support Specialist should allot 30 minutes for the intakes. Intakes will start the first day of Orientation and will take place throughout Orientation week.

1. Intake questionnaire located in Apricot.

2. Discuss confidentiality and mandated reporting.

3. Assess potential barriers (transportation, childcare, mental health, housing etc.)

4. Reenforce the importance of reliable transportation and establish a Plan A and Plan B for arriving at training every day and on time (discuss the impact on attendance).

5. Enter your intake note in Apricot.

Preparation for Cohort/Create Syllabus
✓ Build cohort course in Schoology- Learning Manager sends email when course is available for new cohort.
✓ Prior to the start of your cohort create your class syllabus. ✓ Ensure assessments have a due date.
✓ Send your syllabus to SSM for review and upload to your Schoology course. ✓ Contact & Schedule any Presenters ahead of time to include in your syllabus (i.e.

Financial Literacy Presenter and Laura’s House)

TRAINING

Case Manager Assignment
Employment Readiness Specialists/Coordinators assigns their case load of trainees to themselves at the start of each new cohort. See Apricot Guide for further details.

Creating Goals
The purpose in setting goals with trainees is to help drive them toward improved workforce readiness. As noted in the intake section, prior to intake Employment Readiness Specialist/Coordinator reviews trainees IRIS assessment survey in addition to the information gathered at the intake. The Employment Readiness Specialist/Coordinator will create a IRIS goal and Workforce Readiness goal. The IRIS goal is based on the trainees IRIS assessment.

In addition, to creating a IRIS goal the Employment Readiness Specialist/Coordinator should work collaboratively with the trainee to determine what the trainee needs to address to improve workforce preparedness and together will create a Workforce Readiness goal.

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15 For Trainees that do not have a driver’s permit or valid driver’s license. Employment Readiness Specialists/Coordinators will create a transportation goal (this would be their Workforce Readiness goal). Trainees must be able to demonstrate meaningful advancement of their transportation status prior to training completion:

a. Securing a permit – Minimum level of advancement at end of hard-skills training b. Upon completing permit goal, Employment Readiness Specialist/Coordinator will open Driver’s License goal.
c. Securing a driver’s license – Minimum level of advancement at end of hard-skills training for those with permit at entry

Trainees should have 2 goals, (1) IRIS goal and (1) Workforce Readiness goal (goals should be created by week 2).

When developing goals with a trainee, ensure that they are SMART (specific, measurable, achievable, relevant, and time-sensitive), action oriented and achievable within the timeframe of their program enrollment considering our programs are short term (12 & 16 weeks).

Therefore, the goals determined are goals the trainee can reasonably achieve during the training phase.

Soft Skills For Success
S
•Specific: State exactly what you want to accomplish (Who, What, Where, Why) M
•Measurable: How will you demonstrate and evaluate the extent to which the goal is met? A
•Achievable: stretch and challenging goals wtihin ability to achieve outcome. What is the action- oriented verb?
R
•Relevant: How does the goal tie into the Steps to Success? T
•Time-bound: Set a target date, the "by when" to guide your trainee to successful and timely completion. This doesn't need to be entered into Apricot, but set a target date for the trainee.

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16 The Employment Readiness Specialist/Coordinator is responsible for conducting weekly soft skills class for trainees during training phase. In cases where multiple Employment Readiness Specialists/Coordinators are assigned to a cohort, the ER Manager will appoint one Specialist/Coordinator to take the lead on this.

1. Employment Readiness Specialist/Coordinator to enter accurate attendance for each trainee in Schoology same day group is held.

2. Soft Skills for Success classes are typically held in person.

3. Guest speakers should be scheduled ahead of time, upon syllabus completion.

4. Follow Blended Learning Model:
a. Keep lecture under 30 minutes.
b. Include opportunity for trainee-to-trainee interaction. c. Include small group discussion.
d. Include interactive group learning.
e. Allow time at the end of class for assessment completion.

➢ Below is an example of the SSFS topics:

Soft Skills Topic: Learning Target:

Emotional Self-
Awareness
Read my own emotions and recognize the impact of my emotions.

Order Organize and plan
Duty Display personal self-discipline, reliability, and effective decision making.

Self-Assessment Demonstrate a basic personal awareness of my own strengths and areas for growth.

Self-Alignment Real and ideal self-images are in alignment.

Self-Confidence Demonstrate a healthy feeling of trust in my own abilities and ideas.

Responsibility Purposeful, productive, and dependable
Assertiveness Healthy confidence and self-assurance in social or professional situations Cooperation Work effectively alongside others toward individual or group goals Conflict
Management
Effectively negotiate and resolve conflict when it arises Social-Awareness Recognize the impact of my emotions on others Resiliency Recover from adversity and adapt to change, able to regain positivity Relationship
Management
Effectively engage in interactions with others
Stress Tolerance Endure physical or mental pressure without becoming negative toward myself or others
HEART Presentation Laura’s House, Healthy Relationships Financial Literacy Budgeting, Credit, Identity Theft

1:1 Weekly Trainee Meetings
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17 1:1 Meetings with trainees are mandatory and occur on a weekly basis (at the same scheduled day and time during training). The 1:1 weekly meeting is documented in Apricot within 24-48 hours. Below is an example of a 1:1 meeting.
• Meeting Agenda:
o Begin with a check-in, what’s working & what’s not working, discuss any PC’s given that week. (5 min)
o Update on Workforce Readiness/Review WR tracker (5 min) o Follow up on SSFS Group. Trainees to provide 2 takeaways from the group & how it relates to WR (5 min)
o Work on goals (15 min)

Characteristics of an Effective 1:1 Support Meeting during Training Phase An effective meeting has the following characteristics:
✓ Employment Readiness Specialists/Coordinators assesses how the trainee is coping with the demands of training and address barriers to employment. ✓ Help trainee address challenges and issues that impact their life stability and future ability to work.
✓ Review progress on goals.
✓ Always provide opportunities for trainee to come up with solutions. ✓ Focus on an individual’s strengths.
✓ Take a trauma informed lens.

• If a trainee is tardy or does not show up for a meeting, the Employment Readiness Specialist/Coordinator enters a case note documenting the tardy/missed meeting and informs TS that a PC needs to be issued to trainee for attendance infraction. • If an Employment Readiness Specialist/Coordinator must miss a meeting due to a crisis, emergency, or personal time off the Employment Readiness Specialist/Coordinator should reschedule that trainee for another time in the same week. If a meeting cannot be made up, the Employment Readiness Specialist/Coordinator should check in through email, phone call or teams’ message and notify Employment Readiness Manager.

Case Noting
Well-written case notes provide accountability, confirm the decisions made to deliver certain services and support decisions a staff member has made. Hope Builders staff should use the SOAP format for writing case notes (Please note: The SOAP format has been adapted to fit Hope Builders’ needs and may not be comparable to what agencies outside Hope Builders may use). There are four components to SOAP. They follow:

Subjective (S): What the trainee tells you relating to their goal.

Example: Trainee feelings, concerns, goals, thoughts; intensity of problem

Objective (O): Factual- What was observed or witnessed by staff; what was seen, counted, heard, or measured.

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18 Example: Trainees’ appearance, affect, arrival time, etc.

Action (A): Action/Intervention performed by Employment Readiness Specialists/Coordinators and progress toward goal(s)
Example: What Employment Readiness Specialist/Coordinator did during 1:1 meeting; intervention used by Employment Readiness Specialists/Coordinators, referral provided, trainee progress etc.

Plan (P): What Employment Readiness Specialist/Coordinator plans on doing on behalf of the trainee or plan for trainee to do; date of next meeting or follow up on referral if provided during 1:1.

Example: Next meeting date, follow-up on referral provided

Scenario & Sample SOAP Note:
(S) Trainee shared personal awareness regarding his struggles with showing his emotions and feelings with others. Trainee reported he just holds it all in and has done this since his childhood. Trainee also shared his struggle with time-management.

(O) Employment Readiness Specialist/Coordinator observed trainee was receptive during meeting, as he openly shared areas he struggles with.

(A) Employment Readiness Specialist/Coordinator reviewed and created IRIS goal with trainee to work on balancing self-restraint. Employment Readiness Specialist/Coordinator commended trainee for his transparency and willingness to work towards goals. Employment Readiness Specialist/Coordinator created WR goal to work on Time-Management. Employment Readiness Specialist/Coordinator stressed the importance of attendance and punctuality.

Employment Readiness Specialist/Coordinator provided examples of skills to improve time- management and explained the benefits of practicing these skills while in the program and for future employment.

(P) Employment Readiness Specialist/Coordinator to meet with trainee next week to continue working on goals and action steps.

Do’s and Don’ts – As a general rule, Hope Builders staff should observe some of the following Do’s and Don’ts when writing a case note:

Do’s
• Keep quotes to a minimum and add when necessary.
• Record immediately after meeting.
• Use proper spelling, grammar, and punctuation.
• Document all contacts or attempted contacts.

Dont’s
• Avoid laden language, opinionated statements.
• Avoid using names.
• Don’t procrastinate on notes (case notes are due 24-48 hours) EXHIBIT 3

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19 Hope Builders case notes are to be kept current and documented in Apricot. The Employment Readiness Specialist/Coordinator is responsible for documenting case notes in Apricot within 24-48 hours. In highly sensitive cases, those situations where staff deems it inappropriate to write a case note that is visible to other staff in Apricot, a private case note can be created in Apricot.

Scheduling Trainee Meetings in TEAMS
Scheduling 1:1 check-in in TEAMS will be important for ensuring that trainees are looking at their calendars to see what they have for the day. At HB we use both Outlook and Teams both should sink. All Employment Readiness Specialist/Coordinator meetings/appointments should be scheduled on Teams, even for meetings that are not held virtually, (For 1:1’s that are held virtually the trainee will click on the link to attend).

To schedule Meetings in TEAMS:

1. Open your TEAMS calendar.

2. Click button.

3. Insert day, time, and add trainees to “attendees” row.

4. Add reoccurring status for the duration of training.

5. Click “Save” to send to trainees.

Workforce Readiness WR Team Weekly Huddle
While training is in session, it is important to meet with your team on a weekly basis (or more) as needed, to discuss trainees and be on the same page regarding coaching, PC’s, who is doing well, resources needed, etc. You should be meeting with your WR team at minimum, one 30-minute huddle a week.
*Please note that this is different from the WR Meeting set with management and is executed in addition to.

Inputting Workforce Readiness (WR) Scores
Video Link for Visual Guide
Utilize the HB Workforce Readiness Rubric to score each trainee on a weekly basis within Schoology.
- If your WR meeting is on Monday, WR scores need to be completed by EOD Friday - If your WR meeting is on Friday, WR scores need to be completed by EOD Thursday

To enter scores, follow the steps below.

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20 1. Log in to Schoology.

2. Select your cohort’s “Workforce Readiness” course.

3. Go to the “Gradebook”

4. Under “All Materials”, select “SSS” for Soft Skills

5. Find the correct week of training that you are in and utilize the rubric to determine each trainee’s score for each individual category.

6. Do not manually type in the score. Instead, hover your mouse over the box and click on the square icon that appears and select the score using the pop-up that appears as shown below.

*Please add comments for anyone with less than a 3. Attendance below a 4.0 should always include a note. Positive notes for trainees are also encouraged.

See Pro Tip for Updating WR Assessment Scores for more details.

Entering Attendance
Enter attendance in Schoology.
a. This is important to complete in Schoology each day that you teach. b. It is recommended to start with attendance at the beginning of class. c. If a trainee is marked anything other than a green check mark for “Present”, a note MUST be entered on the attendance log.

Progress Reports (PR)
Progress Reports are given twice within a cohort. CDC will have Progress Reports after week 2 (presented to trainees in week 3). CTP will have Progress Reports after week 3 and week 7 (presented to trainees in weeks 4 and 8). CMA will have Progress Reports after week 4 and week 8 (presented to trainees in weeks 5 and 9).

The lead in your WR meetings will create and send an Excel Spreadsheet with the Progress Reports for each trainee. See example below:

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21 Progress Report Meetings with each trainee will need to occur. PR Meetings typically take 10 minutes or so. To make coordination of meeting possible, it is encouraged to arrange these meetings to be the first 5-10 minutes of the Employment Readiness Specialist/Coordinator 1:1 Meetings. At minimum, 2 of 3 team members need to be present in a PR Meeting. The Employment Readiness Specialist/Coordinator should send the team their scheduled 1:1’s via Outlook calendar. Should the TS members of the WR team not be available, the team can use their huddle time or search alternative routes for when these meetings can best occur.

Follow the steps below with your team.

1. Before scheduling meetings, assign each team member 1/3 of your list of trainees. The trainees assigned to you will be the meetings that you lead (see below). a. For example, if your cohort has 21 trainees, the TS will be assigned 7 trainees, the Employment Readiness Specialist/Coordinator will be assigned 7 trainees.

2. Arrange meeting times and inform trainees about the upcoming Progress Report.

Please ensure that you are available for the PR Meetings of the trainees that are assigned to you in step 1.

3. If you cannot attend a PR Meeting, please write notes for the trainee in the “Areas of Strength” and “Areas of Improvement” boxes noted on the excel spreadsheet prior to the meeting time.
a. Note*: The more meetings that you make yourself available to attend, the less notes you must write ahead of time.

4. Execute meetings.
a. Remember to take turns leading these meetings based on who you were assigned.
b. If no notes are in the “Areas of Strength” and “Areas of Improvement” boxes, assign the non-leading team member to type notes into the boxes while the meeting is occurring for efficiency, these notes can be bulleted/brief since you are going into detail speaking with the trainee.

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22 c. Once the meeting is over and all notes are added, print or email trainee a copy of their progress report.

5. Employment Readiness Specialist/Coordinator will acknowledge in her 1:1 case management case note that the PR was completed and who was present for the WR meeting.
a. Should the meeting have to be scheduled outside of Employment Readiness Specialist/Coordinator one-on-one time, whoever led the PR meeting will need to add a case note on Apricot to document the meeting.

WR Self-Assessments
WR Self-Assessments are created in Schoology in the Workforce Readiness course associated with your cohort. Trainees are asked to complete this self-assessment during orientation, as well as during training. The due date is already pre-set in Schoology for trainees to complete it by deadline time provided: week 3 and week 7 CTP; week 4 week 8 for CMA; and week 2 for CDC.

Please review these assessments with your team and address any prevalent information the following week when meeting with each trainee for Progress Reports.

Additionally, work with your WR team to ensure that the self-assessments are reviewed and graded in Schoology.

Transition Team Meeting with HBCC
An HBCC recruiter will be joining your WR Meeting the last week of training. During this time, you will be discussing trainees, any concerns or barriers that may need to be addressed, and who will be going to extended training versus Career Builder.

END OF TRAINING/CAREER BUILDER
Workforce Readiness Record in Apricot
Once training is complete, the Workforce Readiness Record in Apricot needs to be completed.

This report can be found in each individual trainees “Folder”. There is a section for the TS to fill out and sections for the Employment Readiness Specialist/Coordinator to fill. The Employment Readiness Specialist/Coordinator will fill out the Employment Readiness Specialist/Coordinator section for each trainee and email/notify TS when Employment Readiness Specialist/Coordinator sections are complete.

Extended Training Process (if applicable)
Trainees who are not Workforce Ready at the end of training period (includes externship for CMA), are granted up to 4 weeks of training extension to demonstrate Workforce Readiness.

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23 adequate growth towards meeting goals, the trainee will be dismissed from training and will not advance to Career Builder.

During extended training:
• The trainee will be required to meet with Employment Readiness Specialist/Coordinator 2x a week for case management.
• The Employment Readiness Specialist/Coordinator will create an Action Plan and goals Employment Readiness Specialist/Coordinator will be working on during ET. • Depending on reason for extended training, the trainee may be required to meet with Employment Readiness Specialist/Coordinator & TS for 2x weekly check-ins. o For example, one check-in with Employment Readiness Specialist/Coordinator and one check-in with TS.
• The trainee will be required to participate in any supplemental Hard Skills, Soft Skills, or Employment Readiness tasks related to their goals.
o For example, if they need to demonstrate stronger grades, the TS may work with them as well to increase their knowledge. If they need to show accountability in meeting deadlines, the TS may assign them a Hard Skills assignment to complete.
• The trainee will be allowed to keep their Chromebooks during extended training. It is the responsibility of the TS to collect the Chromebook upon completion of extended training.
o Note: Trainees final stipend will be held if the trainee does not return the Chromebook by the date designated by TS.
• The TS will be responsible for completing the Stipend Roster for the trainees in extended training.

Once a trainee is in the Career Builder stage, HBCC will reach out to them monthly for 6 months to check-in on how their job is going. If there is a barrier during employment or communication with HBCC is a challenge, HBCC will provide a referral to trainee to reach out to Employment Readiness Services for Career Readiness Assistance to work through their barriers or employment skills with an Employment Readiness Specialist/Coordinator.

OTHER DUTIES
Career Readiness Process:

1. When HBCC refers the trainee in Apricot, the trainee will receive an automatic email from Apricot stating they were dismissed from CB and referred to CR for additional support. See sample email below.

Subject: Important Notice: Career Readiness Support
Dear Hope Builders Participant,
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24 We are reaching out to inform you that you have been referred to the Career Readiness program for additional support to enhance your Workforce Readiness skills. Your Support Specialist will be in touch soon to guide you through the Career Readiness process. Please make sure to return their call within 24 hours to avoid being placed on inactive status.

Ms. Michelle Cooper, 714-543-5105 ext.193, [email protected] Ms. Maria Davis, 714-790-8767 ext.145, [email protected] Ms. Maria Plancarte, 714-543-5105 ext.137, [email protected] Ms. Sabine Shah, 714-543-5105 ext.167, [email protected] Ms. Angelica Alvarez, 714-543-5105 ext.147, [email protected] Thank you for your prompt attention.

Best regards,

a. Upon receiving referral:
b. Employment Readiness Manager marks them inactive in Apricot. c. Employment Readiness Manager notifies Employment Readiness Specialist/Coordinator of new CR referral.
d. Employment Readiness Specialist/Coordinator reaches out with one phone call informing them to reach out within 24 hours.
e. Employment Readiness Specialist/Coordinator enters a case note and triggers Employment Readiness Manager, noting contact has been made and participant has been informed if no response in 24 hours, they will remain in inactive status. f. If they respond to Employment Readiness Specialist/Coordinator, Employment Readiness Specialist/Coordinator will assess for commitment. g. If they are committed to CR support Employment Readiness Specialist/Coordinator will notify Employment Readiness Manager, open an action plan and move forward.
h. Employment Readiness Specialist/Coordinator will email Employment Readiness Manager the following information: 60 days from HS to assess for stipend eligibility, and anticipated WR date.
i. Employment Readiness Manager will remove them from inactive status in Apricot.

2. For those marked inactive in CR we will send a quarterly engagement email to invite them to re-engage. See sample email below.

Subject: Re-Engage with Career Readiness Support
Dear Hope Builders Participant,
We are writing to inform you that you are currently on inactive status but remain eligible for Career Readiness support. Our Support Services team would like to re-engage with you and offer assistance through the Career Readiness program. If you are interested in resuming support, please contact Ruth Ibarra, Employment Readiness Manager, at [email protected].

Remember, you have two years from the completion of your training to re-engage and receive these services. We are here to help you achieve your career goals and look forward to supporting you.

Best regards,

a. For those that reach out via email and are interested in CR support. Employment Readiness Manager will ask for their updated contact information and will inform them their Employment Readiness Specialist/Coordinator will contact them.

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25 b. Employment Readiness Specialist/Coordinator makes contact and will assess for commitment.
c. If they are committed to CR support Employment Readiness Specialist/Coordinator will notify Employment Readiness Manager, open an action plan and move forward.
d. Employment Readiness Manager will remove them from inactive status in Apricot.
e. For those trainees that have obtained a career pathway job on their own in the CR phase, Employment Readiness Specialist/Coordinator will assess if trainee has attained the requirements needed:
i. Gather employment information to update Employment Record and confirm job meets career pathway requirements
✓ Start Date:
✓ Company Name:
✓ Company Address:
✓ Position:
✓ Pay Rate:
✓ Hours per week:
✓ Benefits:
✓ Temporary or Permanent:
✓ Placement Method: Self, HB Assisted or HBCC

ii. A Career Pathway job: A middle-skill position in an industry where HB provides training, ensuring long-term employability, and opportunities for advancement within the organization.
✓ It must also offer competitive earnings of $18.50/hr. or more (adjusted annually and at least $2/hr. above minimum wage) OR be full-time, averaging at least 30 hours per week.

f. If a participant meets Career Pathway requirements listed above update their Employment Record in Apricot.

a. Employment Readiness Specialist/Coordinator will create a case note with the following information
✓ Employment Readiness Specialist/Coordinator updated
employment record
✓ Employment Readiness Specialist/Coordinator assessed
participant meets Career Pathway requirements
✓ Employment Readiness Specialist/Coordinator communicated & noted importance of answering all contacts made by HBCC ✓ Employment Readiness Specialist/Coordinator will trigger Employment Readiness Manager on case note
b. For participants who meet the career pathway requirements and are in that position for a minimum of 6 months will be moved to the CB phase by Employment Readiness Manager as they have met full impact.

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INCENTIVE POLICY
For Hope Builders’ Incentive Policy, please see the Stipend Policy.

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PROCUREMENT POLICY & PROCEDURES

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FISCAL POLICIES AND PROCEDURES MANUAL FOR:

Taller San Jose Hope Builders

FEBRUARY 2024

PREPARED FOR FEDERAL AWARDS

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TABLE OF CONTENTS

SECTION 1: INTRODUCTION ...................................................................... 3 SECTION 2: REVENUE – CASH RECEIPTS, ACCOUNTS RECEIVABLE, AND IN-KIND DONATIONS ......................................................................................... 7 SECTION 3: PURCHASING ....................................................................... 12 SECTION 4: TRAVEL AND BUSINESS EXPENSES ............................................. 18 SECTION 5: ACCOUNTS PAYABLE & CASH DISBURSEMENTS PROCESS ................. 21 SECTION 6: PAYROLL PROCESS ............................................................... 24 SECTION 7: FIXED ASSETS ...................................................................... 27 SECTION 8: ASSETS AND LIABILITIES ......................................................... 30 SECTION 9: ACCOUNTING PERIOD CLOSE ................................................... 30 SECTION 10: FINANCIAL PLANNING & OVERSIGHT ........................................ 35 SECTION 11: GRANTS MANAGEMENT PROCESS (INCLUDES FEDERAL AWARDS)...... 41 SECTION 12: FISCAL OVERSIGHT ROLES & RESPONSIBILITIES OF THE BOARD ....... 44 SECTION 13: WHISTLEBLOWER SAMPLE ..................................................... 52 SECTION 14: RECORD RETENTION SAMPLE ................................................. 55 _____________________________________________________________________________________

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3 HB Fiscal Polices & Procedures

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Section 1: Introduction

A. Overview
This manual documents the fiscal policies and procedures to be upheld by Hope Builders (HB). The fiscal policies and procedures ensure sound internal controls, fiscal responsibility, and accountability in accordance with Generally Accepted Accounting Principles (GAAP), and adherence to standards set by the Financial Accounting Standards Board (FASB). As a 501(c)(3) tax exempt nonprofit organization, HB is entrusted with funds granted by foundations and individual contributors and must adhere to the highest standards of accounting.

Fiscal policies and procedures comprise HB’s internal control structure. The control structure’s main objective is limiting any potential unwarranted use of assets or misstatement of account balances. Several basic components of the internal control structure include: (1) the control environment, (2) the accounting system, (3) control procedures, and (4) the accounting cycle.

An organization’s policies and procedur es can dictate its business practices.

Ranging from day-to-day accounting princi ples to board oversight, policies and procedures touch all activities and people at a nonprofit. While it may seem that these policies merely reflect current and/or best practices, in fact they represent the values of the organization. While establishing or revisiting policies, organizations benefit from examining whom the policy impacts and how, whether some individuals or groups might feel the policy’s i m p a c t d i s p r o p o r t i o n a t e l y , a n d w h e t h e r t h e policy perpetuates inequity. Consider policies t h a t a l l o w s t a f f t o p r o p o s e p o l i c y / p r o c e s s updates, the decision-makers, and the expectations. Establish equita ble consequences for not following procedures – the tone at the top matters.

B. Internal Control Structure

1. The Control Environment
The control environment reflects the importance HB places on internal controls as part of its day- to-day activities. Factors that influence the control environment can include the tone at the top set by management and the Board of Directors, organizational structure, ways of assigning authority and responsibility, methods of management and control, personnel policies and practices, protection of informants of improper activities, and external influences such as significant funder expectations.

2. The Accounting System
The accounting system encompasses the methods, accounting software, and records used to identify, assemble, classify, record, and report accounting transactions. Ideally, the accounting system should:
 Identify and record all of HB’s transactions.
 Provide detailed descriptions of transactions allowing for classification in financial reporting.
 Highlight the time period when transactions occurred to ensure they are recorded in the correct accounting period.

3. Control Procedures
Finance &
Equity
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Control procedures are the procedures set up to strengthen HB’s internal control structure and thus safeguard the agency assets. They are divided into the following:
 Segregation of Duties: Allocation of tasks ensures that one individual does not have the ability to both make an accounting error (either intentionally or unintentionally) and also cover it up.
 Restricted Access: Restrict physical access to valuable and movable assets to authorized personnel. Restrict systems access to make changes in accounting records to authorized personnel.
 Document Control: To ensure that all documents are captured by the accounting system, pre-number documents and account for the sequence for documents. To ensure compliance with the Sarbanes-Oxley Act’s provision to prevent destruction of litigation- related documents, HB has adopted policies and procedures for document retention.  Processing Controls: These are designed to catch errors before they are posted to the general ledger. Common processing controls include batch controls, source document matching, clerical accuracy of documents, and general ledger account code checking.  Reconciliation Controls: These are designed to catch errors after transactions have been posted to the general ledger.

4. The Accounting Cycle
The overall purpose of an accounting system is to accurately process, record, summarize, and report on HB’s transactions.

The component accounting cycles fall into one of four primary functions:

I. Revenue, Accounts Receivable, and Cash Receipts
Key steps in this area are:
 Processing cash receipts
 Making deposits
 Recording cash receipts in the general ledger
 Performing month-end reconciliation procedures
II. Purchases, Accounts Payable, and Cash Disbursements Key steps in this area are:
 Authorizing the procurement of goods and/or services
 Processing purchase transactions
 Processing invoices
 Issuing checks
 Recording disbursements
 Performing month-end reconciliation procedures
 Completing year-end reporting for 1099 tax forms

III. Payroll
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The payroll process consists of processing payroll and remitting amounts due to employees, the government, and other agencies such as health insurers, retirement plan trustees, etc.

Key steps in this area are:
 Obtaining and gathering information for processing
 Preparing payroll checks and depositing payroll taxes  Performing month-end reconciliation procedures
 Preparing quarterly payroll tax returns
 Preparing W-2s, the W-3, and other annual payroll tax returns IV. General Ledger and Financial Statements
The general ledger process consists of posting the period’s transactions to the general ledger and preparing the financial statements.

Key steps in this area are:
 Preparing monthly journal entries
 Reconciling bank accounts and other general ledger accounts  Monitoring and reconciling prepaid, accrued, deferred, and fixed asset accounts  Reviewing general ledger activity and posting adjusting journal entries  Producing the general ledger and financial statements C. Key Details

1. Fiscal Year
HB’s fiscal year is July 1 – June 30.

2. Accrual Accounting
HB is on the accrual basis of accounting and uses this system when preparing the organization’s financial statements. Unlike cash basis accounting, which records revenue and expenses based on the timing of cash receipts and disbursements, accrual accounting recognizes revenue when it is receivable and expenses when incurred.

3. Approvals
As an internal control, approval may be required for many of the processes and transactions outlined in this manual. In general, staff will obtain approval from a supervisor. For processes and transactions made by the ED, this individual must obtain approval from the Board of Directors (Board).

4. Board Involvement
The day-to-day fiscal responsibilities of HB are assigned to its management and fiscal staff.

However, ultimate responsibility for the overall fiduciary oversight of the organization rests with the Board.

5. Software and Applications
HB uses the following to process and track financial information:
 Accounting Software: QuickBooks Desktop, Enterprise Version  Development Software: Raiser’s Edge
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 Online Donation System: Stripe, Blackbaud, and Raiser’s Edge  Online Bill Payment System: Chase BillPay
 Payroll System: Paychex

6. Maintenance of this Manual and Exceptions
In order to ensure this manual accurately reflects the financial policies and procedures followed by HB, the Executive Director and the Director of Finance undertake an annual review of this manual. The Finance Committee, on behalf of the Board of Directors, must approve changes and updates to the fiscal policies. In certain cases, exceptions may be made to policies and procedures contained in this manual. All exceptions must be approved by the Director of Finance.

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7 HB Fiscal Polices & Procedures

Section 2: Revenue – Cash Receipts, Accounts Receivable, and In-Kind Donations

A. Overview
HB properly receives, processes, deposits, and records revenue in a timely and appropriate manner. HB ensures that an appropriate segregation of duties, as included in the procedures below, is in place in order to ensure a checks and balances system for the revenue process.

B. Policies & Controls

1. Receive and record cash receipts on a timely basis.

2. Record revenue in accordance with donor stipulations and acknowledge receipt.

3. Store cash receipts in a secure, locked location prior to deposit.

4. Monitor all receipts due to the organization for likelihood of collection and create adequate reserves for uncollectible amounts.

5. Deposit cash and checks within one week of receipt.

6. Guard donor credit card information securely.

7. Sell donated stock within 48 hours of receipt. Value contribution income at the sale price and record any realized gain or loss on sale on the day of the sale of the stock.

8. Analyze proposed donations of goods and services for usability prior to acceptance. If the goods or services cannot be effectively used by HB, reject or donate them to another public charity, or otherwise discard them.

9. Periodically review activities for applicability to the IRS Unrelated Business Income Tax (UBIT) definition.

C. Process Description

Revenue Categories

TYPE DEFINITION EXAMPLE
Accounts Receivable Revenue pledged or earned but
not yet received in cash.
 Pledges Receivable
 Grants Receivable
 Accounts Receivable
Cash Receipts
Revenue received as a donation or
as a payment for services that HB
provides.
 Cash
 Checks
 Electronic/Wire Transfers
 Credit Card payments via
Stripe and Blackbaud
In-Kind Donations
Donations of goods or services to
be used for internal operations
and/or programs.
 Supplies
 Space
 Professional Services
 Items for auction

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Revenue Classifications

TYPE DEFINITION
Revenue without Donor
Restrictions
Contributions for which purpose or timing of use has not been restricted by donors. Includes earned revenue and interest income.

Revenue with Donor
Restrictions
Contributions for which purpose or timing of use has been restricted by donors.

May be further categorized as Temporarily or Permanently restricted:

 Temporarily restricted contributions are grants/gifts which are received with donor stipulations limiting use of the contribution by time or purpose.
 Permanently restricted contributions are grants/gifts where the donor states that the donation must be maintained permanently but may permit the organization to expend part or all of the income derived from the asset.
 Interest earned on an endowment may be purpose restricted by the donor(s) but is often unrestricted.

Pledges, also called promises to give, are written commitments to contribute cash or other assets to the organization.

Understanding Pledges

TYPE DEFINITION TREATMENT
Unconditional Pledge
Agreement to contribute does not
depend on the occurrence of a
specified future and uncertain
event.
 Recorded as income at the
time the pledge is made.
 Create an Allowance for
Doubtful Accounts (5-10%
of pledged revenue
recommended).

Conditional Pledge
Agreement to contribute
dependent on the occurrence of a
specified, future, and uncertain
event.
 Not recognized as income.
 Once the condition has
been met, the pledge
becomes unconditional
and is then recognized as
income.

Donor-imposed Restriction Limits the use of the contributed asset to a specific purpose.

Donor-imposed Condition
Specifies a future and uncertain
event that must take place. If this
event does not occur, the donor is
released from the obligation to
contribute assets.

All pledges and promises to give, along with supporting documentation, are communicated to Finance on a Pledge Form. The Director of Finance, with assistance from the Donor Relations Manager, determines if the pledge can be recognized as revenue, either with or without restriction, based on GAAP guidelines. The documentation for promises to give must include:
 The name of the donor
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 The amount of the gift
 When the payment of the pledge is expected
 Any restrictions on the use of the donation
Unrelated Business Income Tax
UBIT is tax on activities not related to the mission of a 501(c)(3) tax exempt organization. Under IRS publication 598 (Tax on Unrelated Business Income of Exempt Organizations), an organization is subject to UBIT if the activity meets all of the following three requirements:

1. Trade or business

2. Regularly conducted

3. Not substantially related
Earned Revenue
 Partnering Agency Contracts: HB provides supplemental programming through partnerships with local colleges and other educational institutions. This income comes in two ways:
o HB proposes a scope of work and service fee for supplemental programming and contracts directly with a school. HB invoices schools for payment according to the contract terms. This earned revenue is unrestricted.
o HB provides educational programming as a subcontractor for San Jose City College and other organizations on a reimbursement basis. Based on a proposed budget, both parties sign a reimbursement-based contract. HB submits invoices with detailed expense reports and records funds as Tuition Revenue in the accounting software.
 Subtenants: HB acts as a sublandlord and subleases portions of its leased office space to subtenants. HB maintains a detailed sublease with each subtenant that covers all terms of the agreement. HB invoices its subtenants for rental fees on a monthly basis. This earned revenue is unrestricted and is recorded in the accounting software as Space Rental Income.
 Fiscal Sponsorship: HB acts as a fiscal sponsor for certain projects that align with HB’s mission. HB maintains a detailed Memorandum of Understanding (MOU) with each sponsored project covering all terms of its fiscal sponsorship of the project. In return for the services described in the MOU, HB retains a percentage of funds received by each project. This earned revenue is unrestricted and is recorded in the accounting software as Fiscal Sponsorship Fees.

D. References
Pledge
Form/Communication
A donor fills out and signs a form created for each campaign, or provides another form of written documentation, to communicate their pledge to give monetary support.

E. Procedures

Exec.

Dir.

Dir. of
Finance
Staff
Acct.
(D.B)
Acct.

Clerk
Deputy
Director
Donor
Relations
Manager
Devt.

Asst.

1. Receive mail and distribute to
appropriate staff.

Receives
checks
from Dev.

X
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Exec.

Dir.

Dir. of
Finance
Staff
Acct.
(D.B)
Acct.

Clerk
Deputy
Director
Donor
Relations
Manager
Devt.

Asst.

2. Copy checks and supporting
documentation, file a copy for
Finance and forward a copy to
Development (for contributions).

Receives
copy for
Finance
X

3. Enter donation information and
code donations in development
software. Provide coding to
Finance as necessary.

X

4. Create batch(es) by revenue
account in development software. X

5. Prepare and make the bank
deposit (at least weekly):
 Prepare deposit slip.
 Deposit at bank.
 Review receipt to verify
amount and account.
 Attach receipt from bank to
cash receipts backup.

X

6. Enter cash receipts into
accounting software, classifying
revenue in accordance with donor
stipulations and satisfying grants
or accounts receivable as
applicable.

X

7. File deposit slips, check copies,
and other supporting
documentation.

X

8. Reconcile batch report from
development software with
checks/cash received (monthly).

X X

1. If received by mail:
 Process credit card through
Development Software.
 Redact credit card
information after credit cards
clear.

N o t i f i e d X

2. If received via Online Donation
System:
 Provide transaction report for
Finance.

N o t i f i e d X

3. Enter new donations in
development software. X

4. Create credit card batch(es) in
development software. X

5. Enter credit card transactions in
accounting software.

X

6. Reconcile development software
batch to bank deposits and online
donation statement (monthly).

X X
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Exec.

Dir.

Dir. of
Finance
Staff
Acct.
(D.B)
Acct.

Clerk
Deputy
Director
Donor
Relations
Manager
Devt.

Asst.

1. Notify Finance department if wire
transfer donation is expected, and
supply coding information.

X

2. Review bank accounts weekly and
notify Development department
of unexpected wire transfers.

X N otified N otified

3. Enter wire deposit in accounting
software. X

4. Enter wired donation in
development software.

X

1. Provide donor with account
information for stock transfer. X

2. Notify Finance department when
stock donation is expected.

X

3. Sell stock within 48 hours of
receipt. X

4. Receive funds from clearing
service for proceeds of stock, and
process following check and cash
procedures above.

X

5. Enter deposit in accounting
software. X

6. Enter stock donation in
development software.

X

1. Determine whether to accept in-
kind donation. X

2. Determine the Fair Market Value
of in-kind donation for the
purpose of recording revenue.

Save documentation.

X

3. Enter donation information in
development software. X

4. Enter donation in accounting
system.

X

1. Reconcile revenue information in
development software to
information in the general ledger
and bank statement.

X X

2. Reconcile bank account at month-
end. X

3. Print acknowledgment letters and
obtain appropriate signature(s).

X X
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Section 3: Purchasing

A. Overview
HB makes purchases are made in order to support its day-to-day activities and services. An appropriate segregation of duties, as included in the procedures, ensures checks and balances in the purchasing process. The following applies to all purchases, including both goods and services.

B. Policies & Controls

1. Report and review all potential conflicts of interest.

2. Purchase goods and services using the best combination of quality, service, availability, and price.

3. Only make and receive authorized purchase commitments.

4. Obtain and submit proper documentation for all purchases.

5. Only authorized personnel are issued credit cards; they must agree to the credit card policies.

6. Authenticate every consulting engagement with an agreement and appropriate documentation of services prior to payment.

7. Review and document each consulting arrangement to ensure that the consultant qualifies for consultant status and not for classification as an employee.

8. Review all agreements on a yearly basis to make sure they remain current. Periodically review the ledger and check against a list of agreements to make sure there are appropriate agreements for all consulting engagements.

C. Process Description
Annual
Conflict of Interest
Staff with purchasing responsibilities, management, and members of the Board of Directors may not participate in self-interested or related party transactions. Each such individual authorized to obligate funds must sign a Conflict of Interest Statement on an annual basis to confirm adherence to the policy and disclose any actual or potential self-interested or related party transactions in writing.

Pre-Purchase
Where we spend our money matters. Vendor selection is a key area in which nonprofits can express their values and serve their mission. During the vendor selection process, many nonprofits cons ider bids from multiple companies or partners, evaluating the options on price, speed, or product quality. What would happen if you expanded this evaluation t o i n c l u d e m e t r i cs like footprint (international corporations vs. local shops), ownership (BIPOC or LGBTQ+ -owned or -led companies), and other areas of mission alignment?

Finance &
Equity
EXHIBIT 3

City Council
15 –
296
6/16/2026

13 HB Fiscal Polices & Procedures

Last updated September 2022
Competitive Bidding
For purchases or contracts costing more than $10,000, staff must obtain three prices prior to purchase commitment. Bids may include online or print advertisements and must detail the vendor, date, cost, and goods/services to be received. HB will identify what factors, materials, services must be fulfilled by contractors to be evaluated. HB will ensure that all prequalified lists of persons, firms, or products which are used in acquiring goods and services are current and include enough qualified sources to ensure maximum open and free competition. Also, HB will not preclude potential bidders from qualifying during the solicitation period.  Sole Sourced Vendors: When only one vendor is available for a product or service, the vendor is considered a sole sourced vendor. Competitive bidding is not required for sole sourced vendors, although staff should check for new and emerging vendors periodically and note any sole sourced vendor purchase. Due to a limited market, HB considers textbook printers as sole source vendors.
 All contractors must incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Such description must not contain features which unduly restrict competition. The description may include a statement of the qualitative nature of the material, product or service to be procured and, when necessary, must set forth those minimum essential characteristics and standards to which it must conform if it is to satisfy its intended use. The specific features of the named brand which must be met by offers must be clearly stated.

Approval

Prior to purchase commitment, staff must complete a Check Request Form for all purchases according to the approval authorization levels in the chart below.

Blanket Purchase Orders
Blanket purchase orders apply to regularly recurring expenses (e.g., utilities, office supplies).

After a supervisor approves a blanket purchase order at the outset of a service engagement or at the beginning of the fiscal year, staff are not required to complete additional bidding, purchase requests, or approvals to process payment during the course of the service engagement or fiscal year.

Consultant Services
Before beginning a consulting arrangement, HB evaluates criteria established by the IRS to confirm if the consultant performing the services qualifies for independent contractor status. In essence, in order to be categorized as a consultant, the party in question should be:
 Largely autonomous in their work
 Not subject to overt direction and control by the person(s) for whom the service is performed
Specific guidance and examples from the IRS may be found in the Employer's Supplemental Tax Guide, Publication 15-A, found online at www.irs.gov.

Staff must complete and obtain approval for any contractor agreement prior to commencement of work.

Purchase Requirements

GOODS OR SERVICES REQUEST APPROVAL DOCUMENTATION
EXHIBIT 3

City Council
15 –
297
6/16/2026

14 HB Fiscal Polices & Procedures

Last updated September 2022

< $1,499
Email or verbal purchase
request
Direct supervisor

 Contractor
agreement (for
services)

Between $1,500 and
$99,999
Complete and submit
Purchase/Check
Request form
Executive Director and a
Direct supervisor
 Contractor
agreement (for
services)
 Competitive
bidding

> $100,000 or outside
of the approved budget
Complete and submit
Purchase Request form
Board approval required  Contractor
agreement (for
services)
 Competitive
bidding
Purchase
Method of Payment
Purchases may be made using one of three methods of payment, listed in order of preference: (1) the vendor invoices HB for the good or service; (2) staff uses a HB-issued credit card; or (3) the employee pays for expenses using their personal funds (i.e., out-of-pocket) and HB reimburses the expense.
 Vendor Invoices: HB processes payments without the vendor invoice only on an exception basis. HB selects invoices based on due dates, discounts available, and availability of cash, and does not process payments for goods not yet received. Vendor invoices must include the following for recording in the accounting system:
o General ledger account(s)
o Class(es)
o Allocation % and/or dollar amount to each account and class o Signature of requestor
 Credit Card Purchases: Individuals may be issued HB designated credit cards for authorized expenses with approval of the ED. Staff may not use corporate credit cards for personal expenses; cash advances on credit cards are prohibited. Cardholders who use HB designated credit cards improperly will be held liable for any and all unapproved purchases and will reimburse HB for unapproved purchases within 30 days of the purchase.
 Out-of-Pocket: Individuals may be reimbursed for purchases using personal or out-of- pocket funds. HB will reimburse out-of-pocket funds through the Accounts Payable process. Staff must submit requests for reimbursement within 30 days of incurring the expense.

Vendor Qualification
HB completes new vendor qualification prior to any purchase..

Accounting Staff must complete a New Vendor Verification Form for all applicable new vendors prior to set up in the Vendor Master File. Any edits to the Vendor Master File are approved on a quarterly basis by accounting staff.

EXHIBIT 3

City Council
15 –
298
6/16/2026

15 HB Fiscal Polices & Procedures

Last updated September 2022

D. References
Conflict of Interest
Statement
This statement must be reviewed and signed by each new employee or Board member with purchasing authority or influence over purchasing.

Contractor Agreement
All consultant engagements must be documented in a formal agreement. In the case the consultant does not provide an agreement, staff may use this template.

Credit Card
Authorization Form
Each staff member who is issued an organization credit card must review and sign this form prior to receipt of the card.

Employee Mileage &
Expense
Reimbursement Report
Used to document receipts for all out-of-pocket expense reimbursements.

Monthly Credit Card
Expense Report
Used to document receipts for all expenses incurred using a HB-issued credit card
Check Request Form
Used for all purchase and check requests involving payment to a vendor. The requester must complete this form for purchases over $1,499 requiring pre- approval. This form must be reviewed and signed prior to purchase commitment by the authorized approver.

New Vendor
Verification Form Must be completed in order to add a vendor to the Vendor Master File.

E. Procedures

Exec.

Dir. Directors Dir. of
Finance
Staff
Acct.
(D.B.)
Acct.

Clerk
Purch.

Req.

3.1 PURCHASING
Goods

1. Ensure purchase is within the
approved budget and obtain pre-
approval for purchase either
through email or on the
Purchase Request Form
according to the thresholds
above.

Approve
as needed Approve X

2. For purchases of $5,000 or more,
conduct comparative price
shopping and document the
results using the Purchase
Request Form.

Approve
as needed Approve Receive
Form X

3. Make the purchase. If possible,
request that the vendor invoice
HB for the purchase.

X
EXHIBIT 3

City Council
15 –
299
6/16/2026

16 HB Fiscal Polices & Procedures

Last updated September 2022

Exec.

Dir. Directors Dir. of
Finance
Staff
Acct.
(D.B.)
Acct.

Clerk
Purch.

Req.

4. Receive goods (if applicable) and
forward to purchase requestor to
ensure order is accurate.

X

5. For purchases made via vendor
invoice or submit the following
to Finance:
 Purchase Request Form (if
applicable)
 Signed Check Request Form
 Invoice
 Packing Slip (if applicable)

For purchases made with a HB
credit card or out-of-pocket
funds, submit the following to
Finance:
 Purchase Request Form (if
applicable)
 Signed Employee Mileage &
Expense Reimbursement
Report or Monthly Credit
Card Expense Report, as
applicable
 Credit Card Statement (if
applicable)
 Receipt(s)

Receive,
Review, &
Reconcile
Forms to
Invoices
X

6. Enter vendor into accounting
software, if applicable.

A pprove X

7. Record purchase in accounting
software. A pprove X
Services

1. Ensure purchase is within the
approved budget and obtain pre-
approval for purchase on the
Purchase Request Form
according to the thresholds
above.

Approve
as needed Approve X

2. Obtain a signed contract from
the consultant or organization. Review &
Sign X

3. Determine if individual qualifies
as an independent contractor. X

4. Scan contract and set up vendor
in accounting software.

X

5. Record purchase in accounting
software.

A pprove X

EXHIBIT 3

City Council
15 –
300
6/16/2026

17 HB Fiscal Polices & Procedures

Last updated September 2022

Directors Dir. of
Finance
Acct.

Clerk
Staff
Acct.
(D.B.)

3.2 NEW VENDOR SET-UP

1. Determine and complete New Vendor Verification Form
as appropriate:
 Contact information
 Call, email, or website search to gather basic
information
All independent contractors:
 W-9 (US citizen or resident)
 W-8BEN (foreign national working in US)
 CV or equivalent (foreign national working outside of US)
X

2. Enter new vendor into Chase for payment. X

3. Enter new vendor into accounting software, including tax ID. X

4. Attach New Vendor Verification Form to first Purchase Request or purchase that brings vendor to a new level
(in terms of cumulative purchases that fiscal year).

X

5. Approve new vendor upon review of documentation. X

5. Review Vendor Master File annually and ensure all
documentation exists. X X

EXHIBIT 3

City Council
15 –
301
6/16/2026

18 HB Fiscal Polices & Procedures

Last updated September 2022
Section 4: Travel and Business Expenses

A. Overview
This section contains policies and procedures related to authorized expenses as incurred while traveling or conducting business on behalf of and for the benefit of HB.

B. Policies & Controls

1. Obtain pre-approval for out-of-town and overnight travel; keep travel to a reasonable level.

2. Try to find a cost-effective mode of transportation.

3. Submit complete expense reporting, supported with appropriate documentation, on a timely basis for proper processing.

C. Process Description
The primary purpose for HB employees' travel should be for purposes of executing programmatic work, pursuing fundraising opportunities with individual and institutional donors, and for strategic opportunities to increase the visibility, profile, and reputation of HB in accordance with its strategic goals and objectives. When possible, the traveler should make travel arrangements at least 30 days in advance to maximize opportunity for lower fares.

Staff traveling on business related to HB are entitled to transportation, hotel accommodations, meals, and incidentals which meet reasonable standards for convenience, safety, and comfort.

Staff are expected to use discretion and good judgment regarding expenses charged to HB.

Regular commuting costs will not be reimbursed.

Policies around reimbursements represent an organization's values. For example, a policy stating that staff will receive reimbursement at the end of the pay period places undue pressure on individuals whose personal finances do not allow them to wait for such funds. Revisiting an existing policy such as this one helps the organization benefit from examining whom the policy impacts and how, whether some individuals or groups might feel the policy's impact disproportionately, and whether the policy perpetuates inequity. Consider who has access to company credit cards?

Business Expenses

EXPENSE REIMBURSABLE NOT REIMBURSABLE
Airfare / Rail
 Tourist, coach, or economy class
ticket
 Baggage fees for up to one (1)
bag per traveler will be
reimbursed each way
 Internet used
 Business class ticket unless
approved in advance; The
cost of changing a ticket
for non-work-related
reasons
Business-related meals or
meals while traveling on
business
 Reasonably-priced meal
 Up to 20% gratuity
 Not to exceed $59 per day for an
individual when traveling
 When meals are provided
(by HB, hotel, conference,
or other party)
Ground Transportation  Taxi fare plus up to 20% gratuity and/or public transportation

Rental Vehicles  Rental car, gas, tolls, parking,
and insurance
Rental vehicle expenses when
other modes of transit are
Finance &
Equity
EXHIBIT 3

City Council
15 –
302
6/16/2026

19 HB Fiscal Polices & Procedures

Last updated September 2022
Business Expenses
available, practical, and
affordable
Hotel
 Reasonable room charges &
taxes
 Up to $5/day in gratuity
 Extra days at the hotel for
business not related to HB
Personal Automobile
 Current standard mileage rate
set by IRS, tolls, and parking
 Driving directions between
locations serve as appropriate
documentation for mileage
reimbursement

Credit Card Purchases and Out-of-Pocket Reimbursements
Prior to processing credit card payments or employee reimbursements, staff reconcile the documents below and resolve any discrepancies prior to payment:
 Signed Employee Mileage & Expense Reimbursement Report  Coded and signed Monthly Credit Card Expense Report, if applicable  Receipt(s)
The Employee Mileage & Expense Reimbursement Report must be approved by the traveler or purchaser’s supervisor. Expenses should be:
 Reported on a daily basis
 Submitted within 2 weeks of the traveler’s return
Documentation
All expenses need to be supported with appropriate, original receipts. Please number the receipts and reference on the Employee Mileage & Expense Reimbursement Report and Monthly Credit Card Expense Report, as applicable.

Missing Receipts
Staff should make every effort to obtain receipts for credit card and out-of-pocket business expenses. However, in cases where no receipt is available or the employee lost the receipt, they must include a Lost Receipt Form.

Home Office Reimbursement
Employees will receive a monthly home office reimbursement of $50. The staff accountant submits a monthly home office reimbursement request according to an approved work from home schedule.

D. References
Employee Mileage &
Expense
Reimbursement Report
Used to document receipts for all mileage and out-of-pocket expense reimbursements.

Monthly Credit Card
Expense Report
Used to document receipts for all expenses incurred using a HB-issued credit card.

Lost Receipt Form Used to document cases where no receipt is available, or the employee lost the receipt.

EXHIBIT 3

City Council
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6/16/2026

20 HB Fiscal Polices & Procedures

Last updated September 2022

E. Procedures

Employee
Supvr.

Dir. of
Finance
Acct.

Clerk
Employee
Incurring
Expense

1. Incur business or travel expenses, ensuring all
purchases meet the reimbursement guidelines and that
a receipt is obtained for each purchase.

Approve,
if appl. X

2. Complete and submit an Employee Mileage & Expense
Reimbursement Report and/or Monthly Credit Card
Expense Report along with receipts
Approve
Receive
and
reconcile
with
receipts
X

3. Process employee reimbursements according to
guidelines in Accounts Payable. A p p r o v e X

4. Process credit card statement payments according to
guidelines in Accounts Payable. A p p r o v e X
EXHIBIT 3

City Council
15 –
304
6/16/2026

21 HB Fiscal Polices & Procedures

Section 5: Accounts Payable & Cash Disbursements Process

A. Overview
This section refers to the payment of all purchases in which a vendor invoices for goods or services. Some portions of this section also apply to the reimbursement of expenses to HB employees and the payment of HB-issued credit card statements. HB maintains an appropriate segregation of duties, as included in the procedures, to ensure checks and balances in the accounts payable process.

B. Policies & Controls

1. Only make and record authorized and accurate disbursements.

2. Appropriate individuals with fiscal oversight and fiduciary responsibility to the organization review and approve all major expenditures.

C. Process Description
Vendor Invoices & Payments to Participants
HB selects vendor invoices based on due dates, discounts available, and availability of cash and confirms that that the goods arrive within a reasonable period after ordering. Services may include payment prior to delivery, per the agreement. HB processes payments without the vendor invoice or participant voucher only on an exception basis approved by the Director of Finance.

Staff must attach a Payment Request Form to each vendor invoice and include the following for recording in the accounting system:
 General ledger account(s)
 Class
 Project/activity
 Payment date
HB also provides stipends to participants for training and childcare. HB processes payments based off of the approved the Master Training Stipend Roster and Childcare Check Request Forms.

Check Pro
cessing
HB keeps blank check stock in a secure, locked location with access limited to the Director of Finance, Staff Accountant, and Accounting Clerk. Online Bill Payment is used for pre-approved recurring charges, vendor payments greater than $5,000, and the reissuance of lost payments. The Director of Finance also uses Online Bill Payment for vendors that do not accept checks. When appropriate, the Executive Director makes payments electronically (i.e., ACH or wire transfer) rather than by check or Online Bill Payment.

Signatures on checks and releases for wire transfers are obtained in accordance with the approval authorization guidelines below. Checks and BillPay payments are processed weekly.

EXHIBIT 3

City Council
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305
6/16/2026

22 HB Fiscal Polices & Procedures

Last updated September 2022
Approval Authorization Guidelines

METHOD OF PAYMENT THRESHOLD SIGNATORIES/APPROVERS
Checks
 Less than $24,999
 Executive Director
 Deputy Director
 Director of Program
 $25,000 or more  Executive Director

Online Bill Payment
 Less than $5,000
 Executive Director
 Deputy Director
 Director of Program
 $5,000 or more  Executive Director
Intra-Account Transfers  Any amount (Initiation and
release)  Executive Director
Automated Clearing House and
Third-Party Electronic Transfers
(Wires)
 Any amount  Executive Director
Transfers
TYPE Description
Intra-account Transfers Money transferred internally from one HB bank account to another.

Third Party Electronic
Transfers (Wires)
Money transferred externally from HB bank account to a third party’s bank account or for payment.

D. References
Purchase/Check
Request Form
Used for all purchase and check requests involving payment to a vendor. The requester must complete this form for purchases over $1,499 requiring pre- approval. This form must be reviewed and signed prior to purchase commitment by the authorized approver.

Master Training
Stipend Roster Form
Used to communicate a report of all students eligible to receive stipends, and the amounts, to the Accounting Clerk
Child Care Check
Request Form Used for all participant childcare voucher requests

EXHIBIT 3

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6/16/2026

23 HB Fiscal Polices & Procedures

Last updated September 2022
E. Procedures

Exec.

Dir.

Dir. of
Finance
Staff
Acct.
(D.B.)
Acct.

Clerk
Purch.

Req.

5.1 ACCOUNTS PAYABLE & CASH DISBURSEMENTS

1. Complete Check Request Form for vendor
invoices, Master Training Stipend Roster
Form or Childcare Check Request Form, as
applicable, and submit to Finance.

R eceive X

2. Reconcile payment documents and resolve
any discrepancies before entry in accounting
system. Refer to Purchasing procedure 3.1
for required documents.

X

3. Enter payment information into the
accounting software, recording each expense
to the appropriate account, class,
funder/grant, and project.

X

4. Select invoices to pay and approve check
run. Provides
input Reviews X

5. If payment is being made via ACH or wire,
initiate transfer via online banking.

X

6. Retrieve blank check stock and cut checks. R e v i e w X

7. Route checks for signatures with supporting
documentation. X

8. Mail checks. X

9. File all documentation. X

EXHIBIT 3

City Council
15 –
307
6/16/2026

24 HB Fiscal Polices & Procedures

Last updated September 2022
Section 6: Payroll Process

A. Overview
This section applies to the tracking of time worked and the processing and disbursement of salaries to employees. HB maintains an appropriate segregation of duties, as included in the procedures, in order to ensure checks and balances in the payroll process.

B. Policies & Controls

1. Process payroll for work performed.

2. Properly calculate and process payroll amounts and deductions, record them in the accounting system.

3. An individual independent of payroll processing responsibilities verifies payroll for accuracy.

4. Properly communicate, approve, and track employee leave.

5. Record status changes in a timely manner to prevent unauthorized or erroneous payroll disbursements.

6. Maintain and store payroll files securely to limit inappropriate access to confidential information.

C. Process Description
HB calculates gross pay of salaried employees by dividing the annual salary by the number of pay periods during the year. Salaried employees receive the same gross pay each pay period regardless of the number of hours worked. Hourly employees are paid based on the number hours worked, as documented on an approved timesheet, using the most recently approved hourly pay rate for that employee.

HB follows all State and Federal laws and regulations when calculating pay for overtime.

HB processes payroll on a biweekly basis through an outsourced payroll processing company. The payroll processing company provides the following services:
 Calculation and electronic deposit of all federal and state taxes.  Preparation of all quarterly payroll tax returns.
 Preparation of the annual W-2 statements.

Changes to net pay include changes to insurance and other deductions. Staff must complete a Personnel Transaction & Payroll Deduction Form for all actions that create a change in net pay.

In accordance with the Fair Labor Standards Act, all payroll records must show the date, amount, and description of deductions from wages. The employee’s personnel file should contain the original documents supporting the authorization of each deduction.

Finance staff accumulates confidential payroll information, including timesheets and payroll registers, and maintains them in the payroll files, which are stored electronically in a secure location.

EXHIBIT 3

City Council
15 –
308
6/16/2026

25 HB Fiscal Polices & Procedures

Last updated September 2022
D. References
Manual Payroll Check Refers to an off-cycle payroll check that is processed through the Payroll Software and then cut in-house if not electronically delivered.

Personnel Transaction
& Payroll Deduction
Form
Used to communicate new hires, salary changes, and terminations of both hourly and salaried employees. This form is also used to communicate changes to benefits deductions including health insurance, dental, salary garnishments, and other tax-preferred plans. This form must be approved by the employee’s direct supervisor, executive director, and HR Specialist.

E. Procedures

Exec Dir. Dir. of
Finance
Staff
Acct.
(C.B.)
Staff
Acct.
(D.B.)
HR
Specialist All Empls.

6.1 PAYROLL PROCESS

1. Determine allocation of salaries
between programs/function as
well as grants if applicable.

X X

2. Maintain allocations on a
spreadsheet and updates as
needed.

X

3. Using a Personnel Transaction &
Payroll Deduction Form,
communicate the following to
Finance:
 New hire information
 Salary adjustments
 Employee status changes
 Benefits changes
 Changes to payroll
deductions
 Address or personal
information changes
N otified X

4. Complete timecards and obtain
approval from supervisor. X

5. Collect timesheets from hourly
employees. X

6. Add new hires to the payroll
system. X

7. Request vacation time and obtain
supervisor approval. Report other
PTO.

X

8. Prepare and submit payroll to
payroll system for processing. S u b m i t s R e v i e w s P r e p a r e s EXHIBIT 3

City Council
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6/16/2026

26 HB Fiscal Polices & Procedures

Last updated September 2022

Exec Dir. Dir. of
Finance
Staff
Acct.
(C.B.)
Staff
Acct.
(D.B.)
HR
Specialist All Empls.

6.1 PAYROLL PROCESS

9. Import payroll into accounting
system using third-party import
service.

X

10. Ensure that terminated
employees are removed after
their final paycheck has been
processed.

X

11. Review payroll change report to
ensure all changes are accurate
and appropriate before
distribution.

X

12. Perform payroll reconciliations:
 Prior period to current
period payroll register (bi-
weekly)
 Employee deductions to
payments made to insurers
and other benefits providers
(monthly)
 Quarterly Form 941 to GL
(quarterly)
 Gross salaries (per W2
Forms) to GL (annually)
X

13. Maintain payroll files. X

Dir. of
Finance
HR
Specialist
Staff
Acct.
(C.B.)

6.2 MANUAL PAYROLL CHECK PROCESS*

1. Approve the issuance of a manual payroll check. X

2. Submit the manual payroll check information to the outsourced payroll processor on the next payroll submission.

Approve
& submit Enter

3. Input manual payroll check into the accounting software and cut check according to standard Accounts Payable process (see Section 5).

X

4. Submit the manual payroll check information to the outsourced payroll processor on the next payroll submission.

Approve
& submit Enter
*Manual payroll checks will be processed on an exception basis only and are signed by the ED or Director of Programs.

EXHIBIT 3

City Council
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6/16/2026

27 HB Fiscal Polices & Procedures

Section 7: Fixed Assets

A. Overview
This section applies to the acquisition, tracking and disposal of fixed assets. HB must track assets appropriately to ensure the ability to value fixed assets.

B. Policies & Controls

1. Obtain appropriate approval via written requests (supported by sufficient operational and financial justification) for the purchase of capital assets.

2. Identify, tag, track, and inventory all fixed assets inventoried on an annual basis.

3. Only count leasehold improvements and purchases that materially add to the value of the property and prolong the useful life as capital assets.

4. Appropriately record depreciable and non-depreciable fixed assets.

5. Properly authorize and record disposals of capital assets.

C. Process Description
HB considers fixed assets costing $5,000 or more, with a useful life of at least three years, to be capital assets. Note that an exception to this rule may be batch orders of goods with identical useful life that are valued at more than $5,000 in aggregate and are on the same invoice. This should be reviewed on a case-by-case basis. HB calculates depreciation of property and equipment by the straight-line method of the estimated useful lives of the assets. See definitions below for more information.

Understanding Fixed Assets

TYPE DESCRIPTION
Capital Asset Fixed assets costing $5,000 or greater with a useful life of at least one year.

Asset Tag Special identification number that is numerically sequenced and visibly attached to the asset.

Depreciation Calculation used to decrease the value of assets equally over the estimated useful life.

Estimated Useful Life The length of time that a depreciable asset is expected to be useable.

Fixed Asset Tangible property not expected to be consumed or converted to cash in the short-term.

Description of Assets

ASSET CATEGORY ASSET EXAMPLES ESTIMATED USEFUL LIFE
Office Equipment & Furniture Desks, chairs, printers/copiers, telephones 5 to 15 years
Appliances Refrigerators, stoves, washing
machines 3 to 10 years
Leasehold Improvements Replacing floors, tiles, roofing Term of Lease

EXHIBIT 3

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6/16/2026

28 HB Fiscal Polices & Procedures

Last updated September 2022
Capitalization of Expenditures
HB considers capital expenditures to be the following: expenditures that increase the value of property, extend its life, or alter it to a new or different use. HB also capitalizes significant improvements to property leased by HB, including improvements that add value to the leasehold.

Basis for Cost
The accounting records show the depreciable assets at the acquisition cost. Acquisition costs include the invoice price plus all expenses incurred to prepare the asset for operation, including such costs as preliminary engineering studies and surveys, legal fees to establish title, installation costs, freight, and labor and material used in construction or installation.

Non-depreciable capital assets (e.g., land) are carried in the records at the original net cost.

Determination of Useful Life
When HB acquires an asset, the Director of Finance estimates its useful life using such indicators as terms of time, units of production, or hours of service. The cost of an asset is determined over its useful life via depreciation or depletion. When an asset has an indeterminable useful life, such as that for land, HB does not depreciate it.

In the event of a significant change in the estimate of the remaining useful life after the asset has been placed into use, HB will distribute the remaining cost to be depreciated over the revised remaining life.

Fully Depreciated Assets
Fully depreciated assets remain in the fixed asset ledger with the related accumulated depreciation as long as the property is still in use to ensure accurate tracking and safeguarding of assets.

Asset tagging for government-funded organization
When HB uses government contract funds to acquire assets, these cannot be treated as fixed assets belonging to the organization. Staff should identify and tag such assets appropriately and keep them available for inspection in case of an audit.

D. References
Asset Disposal Form Used to track and obtain approval for the disposal of capital assets.

E. Procedures

Dir. of
Finance
Staff Acct
(C.B.)
Ops. & IT
Manager
Empl. w/
Asset

7.1 ASSET ACQUISITION PROCESS

1. Obtain capital asset according to the purchasing
guidelines in Section 3. X

2. Upon receipt of capital asset, label item with
organization name and identifying number. X

3. Assign the asset an estimated useful life. X
EXHIBIT 3

City Council
15 –
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6/16/2026

29 HB Fiscal Polices & Procedures

Last updated September 2022

Dir. of
Finance
Staff Acct
(C.B.)
Ops. & IT
Manager
Empl. w/
Asset

7.1 ASSET ACQUISITION PROCESS

4. Enter asset information into the Fixed Asset Tracker and share with Finance. The fixed asset tracker should
contain the following information:
 Name and description of asset
 Estimated useful life
 Tag number
 Serial number, model, or other identification
 Vendor name, acquisition date, and cost
 Location and condition of asset
 Disposition data, including date of disposition
X

5. Enter asset information into the Fixed Asset Depreciation Schedule. X

6. Track depreciation of assets and adjust amounts in
accounting system on a monthly basis.

X

7. Complete physical inventory of capital assets and
reconcile to fixed asset inventory (annually). X X

Dir. of
Finance
Staff Acct
(C.B.)
Ops. & IT
Manager

7.2 ASSET DISPOSAL PROCESS

1. Prepare and submit Asset Disposal Form to Finance, including:
 Description of asset
 Reason for disposal
 Method of disposal
Approves X

2. Dispose of the asset through retirement or sale. X

3. Remove asset from fixed asset tracker. X

4. Forward approved Asset Disposal form and retirement or sale information to Finance. R e c e i v e X

5. Remove asset from fixed asset depreciation schedule and make appropriate adjustments to asset accounts in the accounting system. X

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30 HB Fiscal Polices & Procedures

Section 8: Assets and Liabilities

A. Overview
This section refers to the approval of taking on long-term debt as well as the process for investments. HB should implement these procedures in accordance with the investment policy and the roles and responsibilities of the Board as they relate to long-term debt and investments.

B. Policies

1. Properly approve, document, and record all long-term debt.

2. The Board of Directors sets the investment policy to determine how assets are purchased and sold.

3. Properly approve, document, and record the purchase and sale of investments.

4. Properly reconcile investment statements to the supporting books and records on a periodic basis.

5. Limit access to the organization’s credit line to authorized users for appropriate uses.

Monitor and reconcile the credit line monthly.

C. Process Description
Assets: Investment Purchase and Sale
The Board approves the investment policy set by the Finance Committee to determine how assets are purchased and sold.

Liabilities: Assumption of Long-term Debt
Staff or Board members present proposals to issue debt to the Board, including bonds payable, notes payable, lease obligations, and pension plan obligations. In its approval, the Board should have a proper understanding of the obligations of the debt and the organization’s ability to meet those obligations. The Board prepares a resolution to document the Board’s approval of the issuance of the debt. If there are any assets collateralizing the debt, HB keeps a register specifically identifying them, updating this register periodically with the current book value of the assets.

HB records debt at the present value of future cash flows and accounts for a discount or premium using the effective interest method.

D. Procedures

Exec.

Dir.

Dir. of
Finance
Staff
Acct.
(C.B.)
Finance
Comm.

8.1 INVESTMENTS

1. Set investment policy; review on an annual basis. Provide input
Provide
input X

2. Enter investment income in the accounting software on a monthly basis. Forward
statement X

3. Reconcile investment accounts to bank statements on a monthly basis. Review &
approve X

4. Distribute reports detailing the earnings and activity in all investment accounts to the Finance Committee on a
bimonthly basis.

X

Section 9: Accounting Period Close
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A. Overview
This section applies to the closing processes that occur at month, quarter, and year-end. The close process results in a set of financial statements that provide critical information as to the financial performance and condition of HB. The primary purpose of closing procedures is to bring control, reliability, and audit-ability to the accounting process. Finance completes close process with information submitted by staff on a regular basis (outlined in sections 3 and 4).

B. Policies & Controls

1. Staff provide information critical to the close process to Finance in a timely manner.

2. Perform a monthly, quarterly, and annual closing process of the accounting records in a timely manner.

C. Procedures
Period Target
Date*
Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct.
(C.B.)
Acct.

Clerk Devt.

9.1 CURRENT ASSETS
Cash Receipts

1. Print cash receipts summary
reports after final day's receipts
are recorded.

Month 5 X

2. Review cash receipts and post to
GL, if not already posted.

Month 5 Review Enter

Cash Accounts

1. Complete bank reconciliations
for each cash account
Month 10 Review &
approve
X

2. Analyze aging of un-cleared
checks and clear stale checks as
appropriate. Follow up on
significant outstanding amounts,
including outstanding checks
issued to employees.

Month 10 Review X

9.2 REVENUE RECOGNITION ACTIVITIES
Accounts Receivable

1. Generate and analyze Accounts
Receivable aging report. Follow
up on significant outstanding
amounts.

Month 5 Review X
Follow up
on
outstandi
ng
pledges

2. Post interest and dividends
income to GL Month 10 Review X

3. Post grants and pledges
receivable to GL as per executed
award letters/contracts and
pledge forms.

Month 10 Review X
Provide
pledges
and
awards

4. Prepare and send invoices for
amounts owed to the
organization.

Quarter 15 X
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Period Target
Date*
Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct.
(C.B.)
Acct.

Clerk Devt.

5. Reconcile revenue reports from
the development software and
make any necessary updates to
the GL.

Month 10 Review X X

6. Reconcile investment income. Month 10 Review X

9.3 OTHER CURRENT ASSETS
Prepaid Expenses

1. Adjust pre-paid expenses (e.g.,
insurance, real estate taxes,
interest expense, etc.) to
recognize expense in proper
month.

Month 10 Review X

9.4 ASSET ANALYSIS
Fixed Assets

1. Record depreciation amounts for
capital assets according to
approved depreciation schedule.

Month 18 X

2. Review new fixed asset
purchases made in the previous
month to verify they have been
recorded properly with the
correct depreciation schedule.

Quarter 30 X

3. Review disposals of fixed assets
and adjust the fixed asset ledger
and appropriate.

Quarter 30 Approve X

4. Reconcile fixed asset ledger to
year-end fixed asset inventory.

Annual 30 Approve X

9.5 NET ASSETS

1. Analyze classifications of net
asset accounts to ensure net
assets are appropriately
classified as unrestricted,
temporarily restricted, or
permanently restricted.

Month 20 X Provide
input Provide
input

9.6 ACCOUNTS PAYABLE

1. Review credit card statement;
match to supporting
documentation for approved
travel and business expenses and
verify coding.

Month 5 Review X

2. Review expense reports; match
supporting documentation for
approved travel and business
expenses and verify coding.

Month 5 Review X

3. Follow up with staff on missing
documentation as needed.

Month 5 X
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Period Target
Date*
Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct.
(C.B.)
Acct.

Clerk Devt.

4. Review A/P and other payables
for possible accruals, and post to
GL.

Month 10 X

5. File annual property taxes. Annual 30 X
Payroll Activities

1. Enter payroll to GL via download
from Accounting Software.

Bi-weekly 2 Review &
approve
X

2. Perform payroll reconciliations. Month 3 Review &
approve
X

3. Record FSA withdrawals in
accounting software Month 15 Review &
approve X

4. Perform reconciliations of all
benefit liabilities (401K, FSA,
etc.)
Month 15 Review &
approve X

5. Perform reconciliation of payroll
taxes (Form 941). Quarter 30 Review &
approve X

6. Track employee vacation and
other PTO and record accrued
leave balances in accounting
software.

Annual 15 X

7. Perform reconciliation of gross
salaries (W-2 Forms). Annual 30 Review &
approve
X

9.7 NOTES PAYABLE

1. If applicable, analyze notes
payable accounts (e.g., notes
payable for mortgages or lines of
credit) and post any unrecorded
interest and principal amounts.

Month 15 Review X

9.8 FINANCIAL REPORTING AND FORECASTING ACTIVITIES

1. Update cash flow forecast. Month 15 X

2. Run preliminary budget-to-actual
expense reports.

Quarter 20 X

3. Run preliminary balance sheet,
including detail on AR and AP. Month 20 X

4. Perform necessary review and
analysis of month-end financial
data.

Month 22 X

5. Review budget-to-actual reports,
balance sheet, and AR and AP
aging prior to preparation of full
financial report package.

Bi-
Monthly 22 X

6. Generate investment report. Quarter 22 X
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Period Target
Date*
Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct.
(C.B.)
Acct.

Clerk Devt.

7. Draft management narrative to
accompany financial report
package.

Bi-
Monthly 25 X

8. Generate full final financial
package and complete financial
statements for management
team and Board of Directors.

Bi-
Monthly 25 X

9. Distribute reports to
management. Month 27 X

10. Distribute reports to Board of
Directors.

Quarter 27 X

11. Meet with Department Heads to
discuss variances.

Month 30 X

12. Generate financial grant reports
for funders.

As
Needed N/A Provide
data X
*Number of calendar days following end of period.

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Section 10: Financial Planning & Oversight

A. Overview
This section applies to the budgeting, cash management, internal and external financial reporting, and audit processes. The annual operating budget is a managerial tool HB staff and board use to facilitate decisions regarding the allocation of resources. Financial reports are managerial tools used to communicate the financial activities of the organization to managers, the Board, and outside organizations.

B. Policies

1. Maintain a comprehensive chart of accounts and review it annually (including Cost Centers). Mark any inactive accounts/cost centers as such, adding new accounts only when necessary.

2. Produce a budget on an annual basis and obtain Board approval prior to end of fiscal year.

Any significant increases or decreases to the budget require additional approval.

3. Forecast cash balances on a regular basis and take appropriate steps to ensure the availability of liquid reserves sufficient to meet ongoing obligations.

4. Enter into relationships with banking institutions only with appropriate authorization.

5. Reconcile bank accounts in a timely manner, led by someone who is not an authorized check signer.

6. Produce bi-monthly financial reports for management and the Board on a timely basis to ensure proper controls of the accounting process, and to facilitate effective monitoring and oversight.

C. Process Description

Chart of Accounts and Cost Centers
The chart of accounts is a listing of all the accounts that make up HB’s accounting system, providing the framework for defining every transaction in the organization. Additional segmentation in the accounting system is used in conjunction with the chart of accounts to capture all relevant information for each revenue and expense transaction. Each year, HB reviews and updates its chart of accounts and system for coding revenues and expenses with the goal of increasing accuracy, efficiency, and effectiveness.

Accounting Segments

SEGMENT DEFINITION EXAMPLES
Chart of Accounts
 A listing of all the natural
accounts that make up
the accounting system.
 Assets and Liabilities
 Net Assets
 Revenue and Expenses
Fund
 Segmentation by type of
funding, and availability
of funds for use.
 Without Donor Restriction
 With Donor Restriction
Organizational Functions
 Segmentation to capture
relevant information for
each revenue and expense
transaction by functional
area.
 Program
 Administration
 Fundraising
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Classes
 Segmentation to capture
relevant information for
each revenue and expense
transaction by program or
function.
 Applicant
 Trainee
 Career Builder
Sub-Classes
 Segmentation to capture
relevant information for
each revenue and expense
transaction by
project/activity.
 Outreach
 Construction Technical
Program
 Career Readiness
Customer/Job
 Segmentation to capture
relevant information for
each revenue and expense
transaction by revenue
source or grant.
 Irvine Foundation
 City of Anaheim
 City of Santa Ana

Budget Development
The annual operating budget is a managerial tool used for planning and facilitating decisions regarding the allocation of resources. The budget expresses in financial terms the mission and goals of the organization. It is also a means of monitoring results to ensure that financial activity conforms to the plan. Staff begin the budget development process no less than 3 months prior to the end of the fiscal year and obtains Board approval prior to the start of the fiscal year.

Financial Reporting (Internal)
Financial reports are managerial tools used for reporting the financial activities of the organization to management and the Board. Careful analysis of financial reports allows measurement of past performance and helps predict future performance. Results of this analysis assist in making decisions that affect the resource allocation.

Internal Reports

REPORT NAME DEFINITION/PURPOSE DISTRIBUTION
Budget vs. Actual
 Organization-wide
 By class
Provides comparison of HB’s
budget to actual revenues and
expenses.
 Department/ Work Team
Heads
 Management
 Board of Directors
Statement of Financial Position
Provides a snapshot of HB’s
assets, liabilities, and net assets.

Also referred to as the Balance
Sheet.
 Management
 Board of Directors
Cash Flow Forecast Indicates expected cash receipts
and disbursements.
 Management
 Board of Directors
AR and AP Aging Reports
Lists of receivables and payables
showing length of time
outstanding.
 Management

Management Narrative
Written analysis summarizing
operating results and highlighting
significant fluctuations between
the budget and actual results.
 Management
 Board of Directors

Financial Reporting (External)
HB is audited annually by an independent external auditor. The audited financial statements are the auditor’s attestation that the financial records of the organization are complete and accurate EXHIBIT 3

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according to GAAP for the fiscal year audited. These statements are distributed to Board members, senior management, and funders. The annual audit includes the reports in the following chart.

External Reports

REPORT NAME DEFINITION/PURPOSE
Statement of Financial
Position
 Provides a snapshot of HB’s assets, liabilities, and net assets at a fixed point in time.
 Also known as the Balance Sheet.

Statement of Activities
 Details income recognized less expense incurred over the course of the fiscal year, resulting in the total change to the net asset balance.  Includes restricted revenue raised for future periods.  Also known as the Income Statement or Profit & Loss Statement.

Statement of Cash
Flows
 Reports the cash inflows and outflows of the organization on an annual basis.
 This statement is used to adjust accrual reporting to obtain a snapshot view of the organization’s position on a cash basis.

Statement of
Functional Expenses
 Discloses expenses by functional classification (Program, Administration, and Fundraising).

Reporting and Audit Requirements
The Audit Committee of the Board reviews and approves the contract with the external auditor annually. HB rotates its lead audit partner a minimum of once every seven years. In addition, HB also issues a formal RFP and conducts a competitive bidding process for external auditors once every five years.

State and Federal Reporting Requirements

TYPE OF REPORT DEFINITION/PURPOSE
IRS Form 990
 Annual report to IRS.
 Public document showing financial position (hard copies must be available to public upon request).
 Prepared two months after annual financial audit.

CA Form 199
 California Exempt Organization annual information return.  Required for CA nonprofits with gross receipts normally equal to or greater than $50,000.

RBF-1 Form  Registration/Renewal Fee Report
 Annual filing to CA Attorney General for charitable organizations Annual Audit
 Annual review of financial records.
 Performed by independent, external auditor.
 According to best practice, should be completed within 6 months after fiscal year close.

Single Audit
 Applicable only if HB expends $750,000 or more a year in federal awards.  Covers the entire operation of the organization, or at a minimum, the departments and/or units that receive and expend federal awards.

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D. References
Chart of Accounts and
Cost Centers
Detailed list of general ledger accounts and segments for tracking additional information related to revenue and expenses

E. Procedures

Exec.

Dir.

Deputy
Dir.

Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct.
(2)
Acct.

Clerk Dirs Devt. Board

10.1 BUDGET DEVELOPMENT PROCESS

1. Establish goals for the
upcoming fiscal year, both
programmatic and financial
in nature.

X Provide
input X Provide
input Provide
input
Provide
input X

2. Designate budget
development team.

Provide
input X

3. Communicate goals,
timeline, and templates in a
budget development kickoff
meeting.

Attend Attend X Attend Attend Attend

4. Distribute historical data and
template for revenue and
expense budgets by
program/function.

X R e c e i v e R e c e i v e

5. Create program/department
expense projections for HB. X

6. Create expense projections
for HB X Provide
input X Provide
input X

7. Create Administration
expense projections and
earned revenue projections.

X X
(Joey)

8. Create contributed revenue
projections.

Provide
s Input X

9. Create earned revenue
projections Provide
s input
X
(Gov.

Grants)
X

10. Assemble individual budgets
into one master budget.

Review
&
approve
X

11. Revise budgets, as necessary,
to meet revenue and
expense targets.

Provide
input
Provide
input X X Provide
input
Provide
input

12. Incorporate adjustments into
full budget, as necessary,
and draft budget narrative.

Review
&
approve
X Provide
input

13. Draft cash flow projection. X
Provide
Input
(Jessica)

14. Present draft budget to
finance committee X Provide
input X

15. Present draft budget to full
Board of Directors. Finance
Comm.

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Exec.

Dir.

Deputy
Dir.

Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct.
(2)
Acct.

Clerk Dirs Devt. Board

10.1 BUDGET DEVELOPMENT PROCESS

16. Approve budget, following
the incorporation of any
requested changes.

X

17. Enter budget into accounting
system. R e v i e w X

Exec.

Dir.

Deputy
Dir.

Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct. (2) Directors Devt. Board

10.2 FINANCIAL MONITORING PROCESS

1. Produce budget-to-actual
reports by program/ function
and organization-wide.

Receive
&
review
Receive
&
review
Support
& review X Receive
& review
Receive
&
review

2. Draft full financial report
package and distribute to the
Board.

Receive
&
review
Receive
&
review
Review
&
approve
X Receive
& review

3. Hold variance analysis
meetings with Department
and Work Team heads on a
quarterly basis.

X Receive
& review
Receive
&
review

4. Reforecast the budget at
midyear, as necessary, to
reflect significant changes.

Keep the original and
reforecast budget in the
accounting system.

Support
&
review
X
Review
&
approve

Exec.

Dir.

Deput
y Dir.

Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct.
(2)
Acct.

Clerk Devt. Board External
Auditor

10.3 ANNUAL AUDIT PROCESS

1. Identify and engage lead
external auditor (every 5
years or as needed).

X

2. Draft audit engagement
letter identifying
services, terms, and
delegations of roles of
responsibilities of HB and
the auditor.

Receive Receive Receive X

3. Define audit timeline and
deliverables with
external auditor.

X Provide
input
Provide
input

4. Hold pre-audit kickoff
meeting to communicate X A t t e n d A t t e n d A t t e n d A t t e n d EXHIBIT 3

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Exec.

Dir.

Deput
y Dir.

Dir. of
Finance
Staff
Acct.
(D.B.)
Staff
Acct.
(2)
Acct.

Clerk Devt. Board External
Auditor

10.3 ANNUAL AUDIT PROCESS
timeline and
responsibilities.

5. Coordinate audit
preparation. X S u p p o r t S u p p o r t

6. Draft necessary audit
schedules.

X X X X

7. Conduct audit. X

8. Provide auditors with
necessary documentation
for testing purposes.

X X X X X

9. Receive audited financial
statements and
management letter.

X X X X

10. Present results of the
audit to the Board of
Directors.

Attend Attend Attend X

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Section 11: Grants Management Process

A. Overview
This section applies to the grants management process, from identifying new funding opportunities to reporting on grants received. HB maintains and monitors all grants in accordance with funder guidelines.

B. Policies & Controls

1. Manage grants to minimize agency risk and maintain fiscal integrity.

2. Appropriately identify, secure, and manage funding.

C. References
Cash Flow Projections Multi-tabbed Excel spreadsheet that captures actual cash received to-date plus projected cash inflows and outlays for organization-wide revenue and expense.

Grant Budget Detail
Sheet
Document prepared to track spend down compliance against a funder-approved budget for each restricted grant and government contract Grant Cover Sheet
Document prepared to communicate to Finance the detailed information needed to account for the grant, such as the funder, amount, grant terms and payment schedule.

D. Procedures

Exec.

Dir.

Dir. of
Finance
Dir. of
Progra
m
Deputy
Dir.

Staff
Acct.
(D.B.)
Donor
Relations
Manager
Devt.

Asst.

11.1 GRANTS AND CONTRACTS MANAGEMENT PROCESS: PRE-AWARD

1. Identify funding
opportunities.

Support
with
new
funding

X
with
Senior
Dir. of
Dev

2. Receive and review RFPs. X

3. Develop and maintain income
projections and funding plan.

Provide
input X
X
with
Senior
Dir. of
Dev
X

4. Develop and maintain a Grant
Budget Detail Sheet to track
expenditures by restricted
grant, program/work team,
and project.

S u p p o r t X

5. Prepare proposals (narrative)
for new or renewed grants. X A s s i s t s

6. Create list of required
supporting documents and
attachments
X A s s i s t s
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Exec.

Dir.

Dir. of
Finance
Dir. of
Progra
m
Deputy
Dir.

Staff
Acct.
(D.B.)
Donor
Relations
Manager
Devt.

Asst.

7. Prepare budgets for new or
renewed grants and projects
as needed.

S u p p o r t
X
with
Director
of
Finance
X
for Gov
grants

8. Coordinate submission of
grant proposals.
 Assemble supporting
documents in Grants
folder
 Delegate responsibility for
submission based on
method (simple email vs.
upload via online portal)
X

9. Receive notification of
funding award and notify
Development.

X X Notified Notified

10. Add award to weekly deposit
report
X

11. Prepare Grant Cover Sheet
and notify Finance. N o t i f i e d X

Exec. Dir. Dir. of
Finance
Dir. Of
Program Deputy Dir. Staff Acct.
(D.B.) Devt. Asst.

Donor
Relations
Manager

11.2 GRANTS AND CONTRACTS MANAGEMENT PROCESSS: POST-AWARD

1. Review the most updated
applicable compliance
requirements and prepare to
answer questions (at outset
of each new contract and at
least once annually)

X X

2. Conduct a kickoff meeting to
discuss details of funding
award, including:
 Timeframe
 Restrictions (including
federal and grant-
specific regulations)
 Reporting and
compliance requirements
X Participate
as needed
Participate
as needed Participate Participate
as needed X

3. Create grant tracking
documents and staff
allocation plan.

X

4. As funds are spent, track
against Grant Budget Detail
Sheet.

X
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Exec. Dir. Dir. of
Finance
Dir. Of
Program Deputy Dir. Staff Acct.
(D.B.) Devt. Asst.

Donor
Relations
Manager

11.2 GRANTS AND CONTRACTS MANAGEMENT PROCESSS: POST-AWARD

5. Collect receipts, payroll
reports, and any other
necessary reporting
attachments on shared drive
for report submission.

X

6. Meet on monthly basis to
monitor programmatic and
fiscal compliance and ensure
funds are spent according to
budget.

X X

7. Monitor receipt of funder
payments and track grants
receivable.

X Provide
input
Provide
input

8. Prepare non-financial reports
to funder.

A pprove X Provide
input

9. Submit final invoice A p p r o v e s X

10. Prepare and submit financial
reports to funder.

Provide
input Provide
input
X
(Gov
grants)
X

11. Create and maintain grant
and funder files.

X
Gov
grants

X
Found-
ation
grants

12. Discusses any need for
extensions, budget
modifications, or other
issues.

X
Approves X
X
Found-
ation
grants
X

13. Perform budget
modifications as agreed upon
by granting agency.

A p p r o v e s X

14. Write justification for budget
modification or extension. X

15. Inform funder of need for
extension and/or budget
modifications.

X
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Section 11a: Grants Management – Federal Awards

A. Overview
This Section provides additional internal controls, practices, policies, and procedures regarding managing Federal awards. The procedures herein aim to safeguard assets and expend funds in accordance to Federal award requirements.

Uniform guidance to administer federal grant awards comes from the Office of Management Office through the documentation found in 2 CFR Part 200 and subparts. Reporting and compliance are two required components to successfully administer grant awards.

B. Description of Policies and Guidelines

1. Payments
This section sets the policies and procedures to comply with 2 CFR 200.302(b)(6).

Hope Builders will always default to seeking or requesting reimbursement for expenses directly or indirectly related to the government grant in accordance to 2 CRF 200.305 (3). This is the preferred method to simplify the processing of government grant payments. Hope Builders management may decide to request an advance depending on the nature of the government grant and project.

Advance payments will only be requested if Hope Builders is able to meet the following:

A. Must maintain or demonstrate the willingness to keep written procedures that minimize the time elapsing between the transfer of funds and disbursement of those funds.

B. Maintain financial management systems that meet the standards for fund control and accountability as established in this part.

C. The funds must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash required to carry out the purpose of the approved program or project.

D. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements for direct program or project costs and the proportionate share of any allowable indirect costs.

E. Timely payment to contractors in accordance with the contract provisions.

Please see section 11 of this manual for all policies and procedures regarding processing of government grant funding.

2. Allowable Costs:

This section sets the policies and procedures when considering Allowable Costs under 2 CFR 200.302(b)(7) and 2 CFR 200.403
HB is responsible for:

A. The efficient and effective administration of the Federal award through the application of sound management practices and executing the unique combination of staff, facilities, and experience to accomplish the goals set forth.

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B. Administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award.

All costs must meet the following general criteria to be allowable under Federal awards as follows (except where otherwise authorized by statute):

A. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.

B. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.

C. Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of HB.

D. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the organization as an indirect cost.

E. Be determined in accordance with generally accepted accounting principles (GAAP).

F. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period.

G. Be adequately documented:
i. All eligible costs supported by source documents (such as invoices, check requests, or similar document) and approved by designated, authorized approvers.
ii. All direct and indirect costs must comply with restrictions, limitations, and conditions of the applicable available grants.
iii. Costs need to comply with other factors (2 CFR 200.403).

H. Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods.

I. Reasonable and necessary costs that are required to operate and manage programs funded by grants.

3. Procurement:

This section addresses the policies and procedures when considering procurement under 2 CFR 200.318.

HB is responsible for properly documenting procurement procedures. See Sections 3 and 7 of this manual for details.

HB will also follow the procurement guidelines set forth by 2 CFR 200.320 when dealing with informal procurement methods, formal procurement methods, noncompetitive procurement methods.

3. Competition:

This section addresses the policies and procedures when considering procurement under 2 CFR 200.319.

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HB is responsible for ensuring that all procurement transactions for the acquisition of property or services required under a Federal award must provide full and open competition. See the competitive bidding section under Sections 3 of this manual for details.

4. Compensation:

This section addresses the policies and procedures when considering compensation and fringe benefits under 2 CFR 200.430. HB employees are hired in a competitive process documented by Human Resources. The job description of each employee’s title can be used to support his/her role and reflect their functions and responsibilities. Actual current compensation rates and fringe benefits as approved by the Executive Director are used to request reimbursement from Federal award agencies. In certain cases, grantors have certain limitations to employee compensation built in their grant agreements. As a grant recipient, HB has been and continues to honor and comply with limitations and conditions of a signed Federal award agreement.

HB is responsible for ensuring that all personnel compensation fall under the proper guidelines and requirements as follows:

A. All personnel salaries will be considered reasonable based on labor market analysis performed by HR and HB Management. This will also include any incentive compensation, awards, performance-based bonuses, etc.

B. HB Management and HR will review each employee and perform a labor market analysis every year during the preparation of the annual budget. HR will compare each employee’s compensation with the adequate labor market analysis reports from outside agencies.

C. HB uses Paychex as the system to properly record and keep the official payroll records. All internal controls between HR and Payroll processing staff will be maintained.

1. HR Staff are responsible for creating and updating personnel files and profiles in Paychex only. They will not be running payroll.

2. Payroll staff are responsible for processing payroll but do not have access to personnel files or profiles.

3. Paychex abides by state and federal employment laws and regulations.

4. Paychex will record all payroll items, job costing, and labor distributions for each employee. All hours and total compensation is imported into QuickBooks. This import clearly outlines all job cost and labor distribution allocations.

D. Time and Effort Procedures:

1. In accordance with 2CFR 200.430 timesheets are utilized to track time and effort. It documents staff time spent on projects and or programs so that the correct grant/fund is charged. Staff codes their timesheet as follows:
 Class Code (identifies the correct program or class in QuickBooks)  Customer Code (identifies the grant)
 Account Number (identifies the account within to the grant)

2. Bi-weekly timesheets are maintained and include the time period and number of hours allocated to each account number and customer code (required for reimbursement by grantor). Staff submit their timesheets Paychex Time and EXHIBIT 3

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Attendance system, and it is reviewed by the Supervisor for accuracy and approves it in the system.

3. Payroll Accountant reviews timesheets to ensure accuracy. Payroll expenditure reports are maintained and utilized as supporting documentation for reimbursement requests. These reports are reviewed by Contracts Coordinator to ensure the actual costs charged to a grant meet contract requirements and within the approved budget for the program.

Please refer to Section 6 of this manual for payroll procedure details.

4. Fringe Benefits:

This section addresses the policies and procedures when considering fringe benefits under 2 CFR 200.431. Fringe benefits are allowances and services provided by HB to their employees as compensation in addition to regular salaries and wages. Fringe benefits include, but are not limited to, the costs of leave (PTO, ETO, sick or military), employee insurance, pensions, and unemployment benefit plans. Except as provided elsewhere, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, HB and employee agreement, or an established policy of HB.

HB is responsible for ensuring that all fringe benefits fall under the proper guidelines and requirements as follows:

A. These fringe benefits must be allocated to Federal awards and all other activities in a manner consistent with the employees whose salaries and wages are chargeable to such Federal awards.

B. Fringe benefits that are classified as direct or indirect costs will also be allocated in accordance with HB’s accounting practices and with the Federal award requirements.

Please refer to Section 6 of this manual for payroll procedure details.

5. Employee Relocation Costs:

This section addresses the policies and procedures regarding employee relocation costs under 2 CFR 200.464.

HB will not be providing any relocation costs to current or future employees at this time. All current recruiting efforts are concentrated on hiring individuals that are local and live within the surrounding area. The Executive Director will be the only person allowed to make and update to this policy when the occasion arises or when it is needed.

6. Travel Costs:

This section addresses the policies and procedures regarding travel costs under 2 CFR 200.475.

Travel costs are the expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of HB. Such costs may be charged on an actual cost basis, on a per diem or mileage basis in lieu of actual costs incurred, or on a combination of the two, provided the method used is applied to an entire trip and not to selected days of the trip, and results in charges consistent with those normally allowed in like circumstances in the HB’s no-federally-funded activities and in accordance with HB travel EXHIBIT 3

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reimbursement policies. See Section 4 of this manual for more details on the travel reimbursement procedures.

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Section 12: Fiscal Oversight Roles & Responsibilities of the Board

A. Overview
The Board provides effective financial oversight, which includes making financial decisions that further HB’s mission, program(s), and goals.

B. Description of Roles & Responsibilities

1. Board Fiscal Oversight Responsibilities
 The Board approves HB’s fiscal policies, adopting and updating them annually.  The Board is aware and knowledgeable of its fiscal responsibilities.  The Board reviews and approves HB’s annual budget. The Board reviews and approves operating, cash, and capital budgets for HB annually, based on Finance Committee recommendations.
 The Board monitors key variances between HB’s budget and the current financial reports on a regular basis. The Finance Committee receives and reviews variance reports as it deems necessary. Staff provide the Board with reports bi-monthly.  The Board approves large expenditures in excess of a pre-determined limit. HB establishes a threshold amount on purchases for which Board approval is required.

2. Roles of the Finance Committee
The Finance Committee takes the lead in reviewing and recommending internal accounting and financial controls, practices, and procedures for HB.

A standing or ad hoc committee of the Board reviews large or unusual purchases, relying on expertise appropriate to the requirements of the decision. Appointed committees are authorized to consult with outside experts, as necessary, to fulfill their responsibility and make recommendations to the full Board on these issues.
i. Overall Responsibilities
 Each Board member of the Finance Committee shall be in good standing and shall be independent in order to serve on this committee.
 At least one member of the Committee shall be designated as Finance Committee Chair by the Board. This member must have a background and expertise in fiscal management or accounting.
 The Committee reviews its charter annually, reassesses the adequacy of this charter, and recommends any proposed changes to the Board. It considers changes that are necessary as a result of new laws or regulations.  The Committee meets at bi-monthly prior to board meetings. The Committee may ask members of management or others to attend the meetings and provide pertinent information as necessary.
ii. Financial Responsibilities
 Ensure that accurate and timely financial information is presented to and understood by the Board.

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 Ensure the distribution of a financial reporting package that provides financial reports with sufficient detail to support the Board’s fiscal oversight responsibilities.
 Ensure that all Board members receive required statements before each board meeting allowing sufficient time for Board members to review.  Regularly review financial results.
 Ensure development of the annual budget, review the proposed budget with management, and recommend final operating budget to the full Board for approval.
 Ensure the budget allows management to make spending decisions within pre- authorized guidelines.
 Perform ongoing monitoring of the budget, including re-estimates, if necessary.  Ensure management has mechanisms in place to monitor the budget on a monthly basis.
 Oversee the management of organization-wide financial assets.  Set investment objectives, strategy, and policy.
 Approves the opening and closing of all HB’s bank accounts.  Establish satisfactory reserves.
 Meet guidelines and requirements set by funders.
 Avoid and resolve conflicts of interest at staff or Board level.  Approve executive compensation level.

3. Roles of Audit Committee
The Audit Committee oversees internal controls and risk-management procedures .
i. Audit Responsibilities
 Appoint the independent auditors to be engaged by HB, approve the audit fees, and pre-approve any non-audit services before the services are rendered. Review and evaluate the performance of the independent auditors and review with the full Board any proposed discharge of the independent auditors.  Review the audit of the financial statements, judgments about the quality (not just acceptability) of organization’s accounting principles, significant changes required in the audit plan, and serious difficulties with management during the audit.  Review all material written communications between the independent auditors and management, such as the management letter.
 Review legal and regulatory matters that may have a material impact on the financial statements.
 Conduct executive sessions with the outside auditors, outside counsel, and anyone else as desired by the committee.
 Inquire about significant risks or exposures facing HB, assess the steps management has taken or proposes to take to minimize such risks, and periodically review compliance with such steps.

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 Review the adequacy of HB’s internal controls including computerized information system controls and security.
 Review procedures for receipt, retention, and treatment of complaints regarding accounting, internal controls, or auditing matters by any party internal or external to HB (Whistleblower Policy).
 Periodically review officer expense reimbursement.

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Section 13: Whistleblower

A. Overview
This section outlines clear procedures for handling whistleblower complaints. The Sarbanes-Oxley Act of 2002, Section 1107, Retaliation Against Informants states that it is illegal to retaliate against a whistleblower. Proper handling of complaints will help protect HB from being accused of retaliation against whistleblowers. To be effective, this policy must be circulated to all employees and board members.

This policy establishes procedures for the receipt and treatment of employee complaints regarding wrongful conduct relating to HB. The policy has been adopted to:

1. Provide employees with a confidential mechanism to alert management of alleged Wrongful Conduct (as defined below). The Finance Committee determines the confidential mechanism and shall outline it in the Employee Handbook.

2. Ensure that all information regarding such conduct is handled in a professional and thorough manner.

3. Protect employees from retaliation for bringing such concerns to the attention of management.

Definition of Standards

STANDARDS DEFINITION
Standards for
Employee Conduct
HB requires employees to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities. Employees must practice honesty and integrity in fulfilling their job responsibilities and must comply with all applicable laws, government regulations and agency rules and procedures.

Definitions of Wrongful Conduct

CONDUCT DEFINITION
Baseless Allegations Claims or accusations made with reckless disregard for their truth or falsity.

Fraudulent or Dishonest
Conduct
A deliberate act or failure to act with the intention of obtaining an unauthorized benefit. Examples:
 Forgery or alteration of documents
 Unauthorized alteration or manipulation of computer files  Fraudulent financial reporting
 Pursuit of a benefit or advantage in violation of the Institute’s conflict of interest policy
 Misappropriation, misuse, or theft of Institute resources, such as funds, supplies, or other assets
 Authorizing or receiving compensation for goods not received or services not performed
 Authorizing or receiving compensation for hours not worked Other Wrongful
Conduct
Examples of other wrongful conduct include:
 Criminal behavior
 Inappropriate behavior towards a coworker
 Other violations of agency policies or applicable laws

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B. Policy

1. Reporting Responsibility
Each employee is responsible for complying with the above standards, and for reporting wrongful conduct or suspected wrongful conduct by other employees. Wrongful conduct includes, but is not limited to, fraud, theft, embezzlement, mishandling of funds, criminal behavior, questionable accounting or auditing practices, inappropriate behavior towards a client or other violations of agency policies or applicable laws.

2. Non-Retaliation
No employee shall suffer harassment, retaliation, or any other adverse employment consequence as a result of:
 Reporting suspected wrongful conduct in accordance with the procedures of this policy;  Providing information, causing information to be provided or otherwise assisting in any investigation, including investigations by local, state, or federal governmental bodies, regarding any wrongful conduct; or
 Filing, causing to be filed, testifying, or otherwise assisting in a criminal, civil or regulatory investigation or proceeding relating to HB.

Employees seeking retaliation against someone who accounts for a violation in good faith shall be subject to discipline including potential termination. By encouraging and enabling employees and others to raise serious concerns within HB, the Whistleblower Policy hopes to initially address the situation internally.

3. Reporting Violations
This Whistleblower Policy encourages employees to share their questions, concerns, suggestions, or complaints about other employees’ conduct with someone who can address them properly. In most cases, an employee’s primary supervisor is in the best position to address an area of concern. However, an employee who is not comfortable speaking with his/her supervisor or is not satisfied with the supervisor’s response is encouraged to speak with his/her Department Head.

Senior managers are required to report suspected violations to HB’s Compliance Officer and/or HB’s General Counsel, who has specific and exclusive responsibility to investigate all reported violations. An employee who is not satisfied or is uncomfortable with speaking to staff members in their department should contact HB’s Compliance Officer directly.

4. Compliance Officer
This role is played by the Finance Committee Chair. The Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at his or her discretion, shall advise HB’s Chair of the Board of Directors if the complaint concerns an alleged violation by the organization President. The Compliance Officer shall have direct access to the Board of Directors and shall report to the Board of Directors at least annually on compliance/whistleblower activity.

5. Accounting and Auditing Matters
The Executive Director shall immediately notify the Chair of the Board of Directors and the Treasurer of the Board of any reported concerns or complaints regarding HB’s finances, including accounting practices, internal controls, alleged malfeasance or illegal conduct, or auditing issues.

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and the Executive Director (unless one or the other is the subject of a complaint) is expected to work with the Board of Directors until the situation is settled.

6. Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith by having reasonable grounds for believing that the activity occurred and have reasonable grounds for believing the information disclosed indicates a violation of the Standards set forth above. Any allegations that prove to be unsubstantiated and which prove to have been made maliciously or with knowledge of their falsehood will be treated as a serious disciplinary offense.

7. Confidentiality
The complainant may submit violations or suspected violations on a confidential basis. Anonymous submissions are acceptable as well. Aligning with the need to execute a thorough investigation, reports of violations or suspected violations will be kept confidential to the extent possible.

Handling of Reported Violations
The Compliance Officer will notify the complainant and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be timely researched and, if stipulated by the investigation, necessary corrective measures will be pursued. The Compliance Officer will update the complainant of the status of the reported violation or suspected violation within 30 business days of the acknowledgement of receipt and will notify the complainant of the investigation into the complaint.

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Section 14: Record Retention

A. Overview
This section applies to the retention, maintenance and destruction of HB’s records and documents. In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding, this policy provides for the systematic review, retention, and destruction of documents received or created by HB in connection with the transaction of organization business.

B. Policies

1. Maintain records as required by government regulations, grant requirements, audit requirements, and other legal needs as may be determined.

2. Obtain Board approval for any exceptions to the record retention requirements.

3. Protect data and information from unauthorized access, use, modification, disclosure, and destruction.

C. Process Description
User Access
Prior to being given access to any confidential information, incoming employees are required to sign a Privacy Policy concerning access to and use of confidential information. HB full implements authorization and privilege controls for the network operating system and applications, as well as specific applications and information.

Maintenance of Accounting Records
The design and implementation of a file structure is critical to having a fully documented, completely traceable, and fully usable accounting system. The types of accounting records the organization maintains include all original documentation submitted to substantiate transactions recorded on the general ledger and the financial reports issued to management, the Board of Directors, and the public.

Accounting File
Maintain electronic and hard copy files which contain the accounting files listed above. Maintain all current hard copies of accounting documents, contracts, and funder agreements at the organization’s main office with access is limited to authorized users only.

Permanent File
Maintain a permanent file including audits, incorporation papers, personnel policies, corporate-by- laws, board reports and other documents that span calendar and fiscal periods in the main office with access limited to authorized users only. Maintain electronic back-up copies and hard copies off-site.

Electronic Financial Records
Access to electronic financial records is available to authorized users on a shared and limited basis. HB incorporates the internal control concept of separation of duties in assigning access to its electronic financial records. Electronic records are backed-up daily and stored on a virtual server.

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D. Procedures
Document Retention Guidelines

TYPE OF DOCUMENT HOW LONG TO RETAIN
Accounting
Annual reports 7 years
Audits:
 Audited financial statements
 Internal audit reports

7 years
3 years
Bank:
 Bank deposit records
 Bank statements and reconciliations

3 years
7 years
Canceled checks:
 Ordinary
 Taxes, property, and important payments

7 years
7 years
Contributions and grants:
 Unrestricted
 Temporarily restricted and perm.
restricted/endowment
 Life income agreement

7 years
Indefinitely
Indefinitely
Expense analyses / distribution schedules 7 years
Fixed asset records, appraisals, depreciation
schedules
7 years
General ledger and subsidiary ledgers 7 years
Physical inventory records 7 years
Purchasing:
 Purchase orders and requisitions
 Invoices (to customers/from vendors)
 Shipping and receiving reports

3 years
3 years
3 years
Taxes:
 Tax returns and worksheets
 Withholding tax statements

7 years
4 years
Vouchers for payment to vendors, employees, and
others 7 years
Donor and Grant Records
Donor records and acknowledgement letters 7 years
Grant applications and contracts 7 years (after completion) Organization Records
Annual Reports to Attorney General Indefinitely
Articles of Incorporation Indefinitely
Board policy resolutions Indefinitely
Charters, constitutions, bylaws Indefinitely
Construction documents Indefinitely
Contracts, mortgages, notes and leases (expired) 7 years Contracts still in effect Indefinitely
Deeds, mortgages, bills of sale Indefinitely
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Document Retention Guidelines

TYPE OF DOCUMENT HOW LONG TO RETAIN
Labor contracts Indefinitely
Fixed asset records Indefinitely
IRS Application for Tax-Exempt Status Indefinitely
IRS Determination Letter Indefinitely
State Sales Tax Exemption Letter Indefinitely
Loan documents, notes Life of loan
Licenses Indefinitely
Minutes from board and committee meetings Indefinitely
Patents and related papers Indefinitely
Trademark registrations and copyrights Indefinitely
Personnel
Accident reports and workers compensation records 7 years (after termination) Employment applications (not hired) 3 years
Employment and termination agreement Indefinitely
Garnishments 7 years
I-9 Forms 3 years (after termination)
Payroll records and summaries 7 years
Personnel files 7 years (after termination)
Retirement and pension records Indefinitely
Timesheets 7 years (after termination)
Insurance
Accident reports and claims Indefinitely
Fire inspection reports 6 years
Group disability reports 7 years
Insurance records (expired contracts) 7 years
Correspondence
General 3 years
Legal and important matters Indefinitely
Electronic Documents
Email 7 years
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EXHIBIT B 1
YSPN MEMBER PERFORMANCE PLAN 2026-2027
Hope Builders

WIOA YOUTH POPULATION
Youth Population Ages # of Youth to be Served
In-School 16-18 0
Out-of-School (75% minimum) 16-24 20

TOTAL NUMBER OF YOUTH TO BE SERVED

PROJECTED ENROLLMENTS & EXPENDITURES
(NOTE: 100% OF YOUTH MUST BE ENROLLED BY 2ND QUARTER-DECEMBER 31, 2026) Quarter # of Enrollments
per Quarter Estimated Expenditures per Quarter
1st 5 $50,000
2nd (100% Enrollment Required) 5 $50,000
3rd 5 $50,000
4th 5 $50,000
TOTAL 20 $200,000
14 WIOA ELEMENTS
mark a “x” next to the elements provided in your
program

PERFORMANCE MEASURES
(Projected Benchmarks subject to change
Baseline=BL )
x 1. Tutoring, study skills training, dropout prevention strategies

1. % of Participants who are in education/training,
or in unsubsidized employment during the 2nd
quarter after exit
Benchmark: 68%

2. Alternative secondary school services or dropout
recovery
x 3. Paid & unpaid work experience that have
academic and occupational components, which may
include: summer employment, pre-apprenticeship,
internships & job-shadowing, or On-the-Job training
(20% of funds must be used for this element)

2. % of Participants who are in education/training,
or in unsubsidized employment during the 4th
quarter after exit
Benchmark: 62%
x 4. Occupational skills training—priority for
recognized credentials aligned with sectors in
demand

3. The median earnings of Participants in
unsubsidized employment during the 2nd quarter
after exit
Benchmark: $4000
*Pending further State and Federal guidance.
x 5. Education offered concurrently with workforce
preparation activities

4. % of participants who, during the program, are
in education or training that leads to a recognized
postsecondary credential or employment AND
who are achieving measurable skill gains
Benchmark: 59%
*Pending further State and Federal guidance.
x 6. Leadership development, community service &
peer-centered activities
x 7. Supportive Services
x 8. Adult mentoring
x 9. Follow-up services for not less than 12 months
after exit (required)

5. % of Participants who obtain a recognized
postsecondary credential or secondary diploma
during participation OR within 1 year after exit
Benchmark: 62%

10. Comprehensive guidance & counseling drug &
alcohol, etc.
x 11. Financial literacy 6. Effectiveness in serving employers Benchmark: BL*
*Pending further State and Federal guidance.

12. Entrepreneurial skills training
x 13. Labor marker information-career awareness and
exploration

14. Activities to help youth prepare for and
transition to postsecondary education
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COMPLAINT HANDLING PROCEDURES

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EXHIBIT C

COMPLAINT HANDLING

UNDER THE
Workforce Innovation Opportunity Act

Santa Ana Local Workforce Development Area
Revised May 20, 2019

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Table of Contents

I. Information Regarding Complaints 3
A. Nondiscrimination and Equal Opportunity Complaints 3

1. Policy Statement 3

2. Civil Rights 4

3. Nondiscrimination laws under WIOA 4

4. How to File Your Complaint 5
B. Criminal Complaints 6
II. General Procedures for Handling Non-Criminal Violations of the Act 6 III. Procedures for Handling Complaints at the LWDA Level 8 IV. Procedures for Handling Complaints at the State Level 12 V. Procedures for Handling Discrimination Complaints by Participants 15 VI. Procedures for Handling Disability Complaints by Participants 17 GLOSSARY OF WIOA TERMS 20

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I. Information Regarding Complaints

A. Nondiscrimination and Equal Opportunity Complaints

1. Policy Statement
In carrying out the purpose of the Workforce Innovation Opportunity Act (WIOA), the City of Santa Ana Local Workforce Development Area (LWDA) will establish programs to prepare youth and unskilled adults for entry into the labor force and to afford job training to those individuals facing serious barriers to employment. Every effort will be made to provide services necessary for eligible individuals to obtain productive employment.

In implementing WIOA, all contractors in the Santa Ana LWDA will foster equal opportunity and non-discrimination, as provided in State and Federal equal opportunity and non-discrimination laws including, but not limited to:

 Title VI of the Civil Rights Act of 1964
 Title VII of the Civil Rights Act of 1964
 The Age Discrimination Act of 1975, as amended
 Section 503 of the Rehabilitation Act of 1973
 Section 504 of the Rehabilitation Act of 1973
 Title IX of the Education Amendments of 1972
 Section 188 of the Workforce Innovation Opportunity Act of 2014

In keeping with our commitment, no individual shall be excluded from participation in, denied benefits of, subjected to discrimination under, or denied employment, in the administration or of in connection with any WIOA funded program because of race, color, religion, sex, national origin, age, disability, or political affiliation or belief.

Participation in programs and activities financially assisted in whole or in part under WIOA shall be open to citizens and nationals of the United States, lawfully admitted permanent resident aliens, lawfully admitted refugee, parolees, and other individuals authorized by the Attorney General to work in the United States.

No individual will be intimidated, threatened, coerced, or discriminated against because of filing a complaint, furnishing information, or assisting or participating in any manner in an investigation, compliance review, hearing or any other activity related to the administration of WIOA.

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Administration responsibility for this Equal Opportunity/Affirmative Action (EO/AA) Program is delegated to the Equal Employment Opportunity (EEO) Officer for the Santa Ana local Workforce Development Area. Equal opportunity and non- discrimination, however, will only be achieved through leadership and implementation of a viable Affirmative Action Equal Opportunity Program.

2. Civil Rights
No one applying for or enrolled in the Workforce Innovation Opportunity Act (WIOA) programs may be discriminated against because of race, color, creed, disability, national origin, sex, age, political affiliation, or beliefs.

This means that – for any of the characteristics listed above:

 You may not be denied the opportunity to enroll in WIOA.  No benefits or services may be denied you for discriminatory reasons.  You may not be segregated or treated any differently from other applicants or participants, while you are being registered, interviewed, counseled or tested; or while you are working or attending classes as part of the program.  You must be provided an equal chance to use all facilities available in the program.
 Fair employment practices must be provided to all staff with regard to recruiting, hiring, transferring, promotions, training, compensation, benefits, layoff, and termination.

You have the right to make a complaint if you feel you have been denied any of the above opportunities. You cannot in any way be penalized for filing a complaint. Your WIOA sponsor has established a mechanism for handling complaints and grievances.

Your complaint must be filed within 180 days. All complaints will be handled confidentially.

3. Nondiscrimination Laws under WIOA

Title VI of the Civil Rights Act of 1964

Prohibits discrimination on the basis of race, color, national origin, or religion.

The Age Discrimination Act of 1975

Prohibits arbitrary discrimination against persons’ age 40-70.

The Rehabilitation Act of 1973
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Prohibits discrimination based on disability.

Title IX of the Education Amendments of 1972

Prohibits discrimination in any education or training program or activity receiving federal financial assistance.

OTHER CIVIL RIGHTS LAWS:

Title VII of the Civil Rights Acts of 1964

Prohibits discrimination in employment based on race, color, religion, sex, or national origin in all terms and conditions of employment and establishes the Equal Employment Opportunity Commission as the administrative agency.

White House Executive Order no. 11246 as Amended by Executive Order No. 11375

Creates the office of Federal Contract Compliance and prohibits discrimination based on race, color, sex, religion, or national origin.

Department of Labor Secretary’s Order no. 4-73

Prohibits discrimination based on sex.

Equal Pay Act of 1963

Prohibits pay differential solely because of sex.

Emergency Employment Act of 1971

Prohibits discrimination based on race, creed, national origin, political affiliation, or beliefs.

4. How to File Your Complaint

a. Put your complaint in writing.
b. Have it sworn to before a notary public, if possible. c. Provides details that tell what happened, where it happened and when it happened.
d. Give the name and addresses of all persons who were present or who had anything to do with the matter.

...Complaints on the basis of race, color, or national origin, age, sex, religion, political affiliation or belief, retaliation and citizenship, must be filed within 180 days of the alleged occurrence directly with:

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6 EXHIBIT C

Director
Civil Rights Center
U.S. Department of Labor, Room N-4123
200 Constitution Ave., NW
Washington, D.C. 20210

Complaints on the basis of disability must be filed within 180 days of the alleged occurrence. These complaints must be filed directly with the WIOA administrative entity. The WIOA administrative entity shall issue a written decision within 30 days of the filing of the complaint. If the complaint is still unresolved, an appeal may be made to the Chief of State Workforce Investment Division Office.

The Department of Labor, the Civil Service Commission, the Equal Employment Opportunity Commission, and many other offices and agencies are committed to assuring equal employment opportunities for all persons. They will protect you.

A case may be taken to court if the other processes do not yield satisfactory results.

You may hire your own lawyer, or if you cannot afford one, the court may appoint one for you.

It is unlawful for an employer, union, or employment agency to punish you or any witness for attempting to present the facts in a case.

YOUR CIVIL RIGHTS UNDER THE

WORKFORCE INNOVATION OPPORTUNITY ACT
Santa Ana Local Workforce Development Area
801 W. Civic Center Drive, Suite 200
Santa Ana, CA 92701
(714)565-2600

B. Criminal Complaints

In accordance with the WIOA and the implementing code of Federal section 667.600....

Federal handling of criminal complaints and report fraud, abuse and other criminal activity. “All information and complaints involving fraud, abuse or other criminal activity shall be reported directly and immediately to the City of Santa Ana and the Secretary of Labor.”

II. General Procedures for Handling Non-Criminal Violations of the Act

The following procedure is promulgated to meet the requirements of Title 20, of the Code of Federal Regulations, Section 186 through 188 of the WIOA regulations, and Section 181 of the Act (Public Law 105.200: 29 U.S. Code Sec. 2931 et seq.) at the State and LWDA level for the receipt, investigation, hearing, and resolution of complaints by WIOA participants, sub EXHIBIT 3

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recipients, applicants for participation, or financial assistance, labor unions, community based organizations, or any other persons.

These procedures provide for resolution of non-criminal complaints arising from the operation of the Santa Ana LWDA.

A complaint is defined here as a written expression by a party alleging a violation of the Act, regulations promulgated under the Act, recipient grants, sub agreements, or other specific agreements under the Act, including terms and conditions of employment of such participants in employment training programs. All complaints, amendments and withdrawals shall be in writing. These procedures are intended to resolve matters which concern policies, procedures or action(s) arising in connection with WIOA programs operated by each LWDA grant recipient and sub recipient under the Act.

These procedures shall not be construed as affecting any other available legal remedy outside of the WIOA complaint process (i.e., disputes regarding terms and conditions of employment of any employee who is not a participant), either separately or simultaneously, that a person may wish to pursue in the resolution of a non-WIOA complaint. Also, these procedures do not restrict the LWDA grant recipient staff in carrying out informal discussion

Procedures do not restrict the LWDA grant recipient staff in carrying out informal discussion and resolution of any problems outside of and without resort to the formal complaint procedure.

A. The following principles and rules apply to all complaints at all steps of the complaint procedures:

1. All complaints must be made in writing within 180 days of the alleged occurrence, except complaints alleging fraud or criminal activity.

2. All persons filing a complaint shall be free from restraint, coercion, reprisal, or discrimination. Good faith efforts shall be made to informally resolve the complaint prior to the scheduled hearing. Complainants have the right to withdraw their complaints (in writing) at any time prior to the hearing. A complainant may amend his/her complaint to correct technical deficiencies but not to add issues.

3. Complainants shall have the right to be represented at their own expense by person(s) of their choosing at all levels of the complaint process.

4. Upon enrollment into employment or training, participants shall be provided with a written description of these procedures, including notification of their right to file complaints and instructions for filing.

An employer of participants, including private-for-profit employers of participants, may use this or other complaint resolution procedures so long as the participant is informed of the complaint resolution procedure they are to follow and the time frames governing review of complaints are met.

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A “participant”, within the meaning of these procedures, is an individual who receives employment-training services under a program funded by Santa Ana LWDA. The Complaint Resolution Procedures contained herein (or the alternative procedures which an employer may use) shall be available to participants to resolve disputes regarding items and conditions of employment of such participants in employment training programs. However, such procedures shall not be used to resolve disputes regarding terms and conditions of employment of any employee who is not a participant, as defined herein.

5. If a complaint does not receive a decision at the LWDA grant recipient level within 60 days of filing the complaint or receives an unsatisfactory decision, the complainant then has a right to request a review of the complaint by the Governor.

6. Complainants must initially file and exhaust LWDA grant recipient/hearing procedures prior to appealing to the State except where the State determines that the LWDA grant recipient’s procedures are not in compliance with the State’s procedures.

III. Procedures for Handling Complaints at the LWDA Level

A. Receipt Complaints

Pursuant to the WIOA regulations found at 20 CFR, Section 683.600, the LWDA administrative entities have the responsibility to conduct hearings and resolve complaints made by individuals about the administration of programs in the LWDA. “LWDA level” encompasses LWDA administrative entity and employers to which the administrative entity has delegated the complaint resolution process. The following comprise the guidelines for resolving issues arising in connection with WIOA programs operated by the Santa Ana LWDA including resolutions of complaints arising from actions, such as audit disallowances or the imposition of sanctions taken by the Governor with respect to audit findings, investigations or monitoring reports.

1. Form and Filing of Compliant

Official filing date of the compliant is the date the written complaint is received. The filing of the complaint with the Santa Ana LWDA Equal Employment Opportunity Officer shall be considered as a request for hearing and a decision must be issued within 60 days.

The complaint must be in writing and must be signed and dated. The complaint should also contain the following information:

a. Full name, telephone number, if any, and mailing address of the complainant;

b. Full name, telephone number, and mailing address of the agency involved (respondent);

c. Clear and concise statement of facts including dates constituting alleged violation;

d. What provisions under the Act, regulations, grant or other agreements under the Act, are believed to have been violated;
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e. Remedy sought by the complainant; and

f. If the complainant is a private or public entity or corporation, and not a natural person, the filing of the complaint must be duly authorized by the governing body of such entity or corporation.

The absence of any of the requested information shall not be a basis for dismissing the complaint.

A copy of the complaint must be sent to the respondent and both parties notified of the opportunity for an informal resolution. At each step of the complaint process, the complainant must be notified in writing of the next procedural step.

2. Informal Conference

Informal conferences will be utilized by the Santa Ana LWDA to resolve complaints; however, such informal conferences shall not extend the time within which a decision must be issued after receipt of a complaint. Attempts at informal resolution will commence with two (2) weeks of the date of filing of the complaint.

a. The EEO Officer will review the case and ascertain facts prior to the conference so that appropriate resolution can take place at the time of this meeting whenever possible.

b. Although the complainant should be encouraged to attend this conference, his/her failure to do so should not preclude his/her right to request a hearing on the matter.

c. If mutually satisfactory resolution results and the Santa Ana LWDA concurs, the EEO Officer will write a brief report for the file stating the issues and resolution. The matter shall then be considered closed.

d. If resolution does not result, the complainant shall be provided the necessary information and assistance to request a hearing if he/she so desires.

3. Request for Hearing

a. As in the case of the complaint, the request for a hearing should be put in writing and be filed in person or by mail. A governing board resolution of authorization to appeal should also be submitted when appropriate. The request should be filled with:

Jennifer Sommers
Sr. Personnel Analyst – EEO Officer
20 Civic Center Drive, M-24
Santa Ana, CA 92701
(714) 647-5348

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b. A hearing will be scheduled by the EEO Officer within thirty (30) days of the date of filing of the complaint.

4. Notice of Hearing

Upon receipt of the request for hearing, the complainant and the respondent will be notified in writing of the hearing ten (10) calendar days prior to the date of the hearing.

The ten-day notice may be shortened with the written consent of the parties. A decision will be issued by the Santa Ana LWDA within sixty (60) days of the date of filing of the complaint.

The hearing notice shall be in writing and contain the following information:

a. The date of notice, name of the complainant, and the name of the party against whom the complaint is filed.

b. The date, time and place of hearing before an impartial hearing officer.

c. A statement(s) of the alleged violation(s)

d. Advise as to where information or assistance may be obtained, and the name, address, and telephone number of the Santa Ana LWDA Equal Employment Opportunities (EEO) Officer who can answer inquiries.

B. Conduct of Hearing
The hearing shall be conducted in an informal manner with strict rules of evidence not applicable. Unnecessary technicalities should be avoided. It should provide the flexibility to enable adjustment to the circumstances presented.

1. The hearing officer shall have complete independence to obtain facts and make decisions. The hearing officer shall be in a position to render impartial decisions and thus should not be subordinate to the Santa Ana LWDA or its sub recipients. The hearing officer will be selected from a list of names on file with the EEO Officer.

2. Full regard must be given to the requirements of due process to insure a fair and impartial hearing.

3. The hearing office designated by the EEO Officer to function in a quasi-judicial capacity should begin the hearing by summarizing the record and the issue and should explain the manner in which the hearing will be conducted, making sure that everyone involved understands the proceedings. Such explanations should be adapted to the needs of the specific situation. The hearing officer might take testimony under oath or affirmation to give some assurance of veracity to the hearing.

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4. The burden of proof should be reasonable and flexible, dependent upon the circumstances of the case involved. The hearing officer determines the order of proof.

Generally, the party making the complaint has the obligation of establishing his or her case and should be examined first.

5. The party involved should have the right to be represented (at their own expense) if he/she so desires. Other he/she is limited to his/her own abilities and those to the hearing officer in obtaining testimony in the case.

6. It is important that the hearing officer obtain the fullest information for the record. If the parties involved, or their representatives, do not know how to ask the right or pertinent questions in pursuing their right to due process, it shall be necessary for the hearing officer to step in to have all the materials and relevant facts elicited.

7. The practice in informal hearings is generally not to apply strict rules of evidence in obtaining facts. However, the quantity of evidence required to support a decision on an issue should be sufficiently credible that the state (or other appropriate agency), upon reviewing the decision, would conclude that the decision is supported by substantial evidence.

8. The hearing officer should attempt to negotiate a resolution of the issue at any time prior to the conclusion of the hearing.

9. Within ten (10) days of the conclusion of the hearing, the hearing officer will issue a recommended decision to the LWDA for final determination. The recommended decision shall be in writing and may be accepted, rejected or modified by the Santa Ana Workforce Development Board.

C. Issuance of Decision

Within sixty (60) calendar days of filing of the complaint, the Santa Ana LWDA shall issue a written decision to all parties by first class mail. The final decision shall contain the following information:

1. The name of the parties involved.

2. A statement of the alleged violation and issues related to the alleged violation.

3. A statement of the facts.

4. The decision and the reasons for the decision.

5. A statement of corrective action, if any, to be taken.

6. Notice of the right to request, within ten (10) calendar days of receipt of the decision, a review of the decision by the State Review Panel.

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D. Record of Hearing
An administrative file containing support documents on the complaint resolution process hearing conducted will be retained by the Santa Ana LWDA. The purpose of a record is to serve as substantiation of the process followed by the Santa Ana LWDA on the resolution of the issues and the results. This information would then be available for subsequent review in the event the matter is raised with the State. Such records must be retained for a three- year period after the grant has been officially closed out.

The Santa Ana LWDA’s written decision will be included in the record. Evidence received at the hearing, notes by the hearing officer, stenographer’s notes and tape recordings may also be used.

E. Establishment of Complaint Procedures
In accordance with Section 683.600, each employing agency including private-for-profit employers of participants under the Act is required to establish a complaint procedure for resolving matters relating to the terms and conditions of employment. Employers may operate their own grievance system or may utilize the Santa Ana LWIDA’s established procedures under Section 683.600. At a minimum these procedures must include:

1. Written notice, upon enrollment into employment training services, of the scope and availability of such procedures. Employer’s grievance procedures shall be set forth in a written document and must meet the regulation mandate that a complaint will be resolved with sixty (60) days from the date the complaint was filed. A copy of employer’s grievance procedure shall be provided to each participant upon enrollment in employment training.

2. Written notice, at the time the grievance is filed, of the procedures under which the grievance will be processed.

3. Written notification of the disposition of the grievance and a written decision shall be issued within thirty (30) days of the filing of the grievance unless a present and long established grievance specifically provides other limits; and

4. Written notification of the participant’s right to request a review of the employer’s decision by the Santa Ana LWDA and the State Review Panel in accordance with Section 683.600.

IV. Procedures for Handling Complaints at the State Level

Section 181 (c) of the Act and the WIOA regulations at 20 CFR, Section 683.600 (d) requires the Governor to establish a State Review process of complaints filed at the LWDA grant recipient level and of complaints initially filed at the State level.

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established at the LWDA level and shall issue a decision based on the information contained therein.

Complaints which may be initially filed at the State level will be heard by an independent hearing officer designated by the State Workforce Investment Division (WID). The hearing officer shall conduct a hearing and issue a recommended decision to the State Panel. The recommended decision shall be in writing and may be accepted, rejected or modified by the State Review Panel.

A. Form and Filing of Complaint.

1. Request for State Review of LWDA Level Decisions

On receipt of a complainant’s request for review because of an unsatisfactory decision, the State shall provide for an independent state review.

2. Filing of Requests for State Review

The State Review Panel shall review all LWDA level decisions when a request for review is filed within 10 days of receipt of the adverse decision. Such requests must be filed in writing with the Chief of the WID Office. The request for review should contain the following information:

a. Full name, address, and telephone number of the party requesting the review b. Full name, address, and telephone number of the other party c. A copy of the decision
d. Brief statement of reasons for review or the section of the LWDA decision to be reviewed including regulatory and statutory citations
e. A statement of the relief sought.

3. Complainant Responsibility

It is the responsibility of the complainant to include in the request for review a written statement setting forth the facts presented at the LWDA hearing which support the requested relief.

The Chief, WID, shall mail a copy of the request for review to the other party and to the LWDA. It shall be the responsibility of the LWDA to submit the complete record including a typed record of the hearing to the Chief, WID, within ten (10) days.

B. Conduct of Hearings.

1. Request for Hearing at the State Level
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If no decision has been issued at the LWDA level or the State has determined an audit disallowance or imposed sanctions, the complainant may request a hearing. The hearing officer will then issue a recommended decision to the State’s Review Panel for final determination.

2. Filing for Request for Review
The request for a State hearing shall be filed within ten (10) days after LWDA should have issued a decision or ten (10) days after the issuance of the audit disallowance or sanction. The request shall be filed directly with the Chief of the WID in writing and should include the following:

a. Full name, address, and telephone number of the LWDA b. Name, address, and telephone number of the LWDA
c. Copies of complaints made at LWDA level from which no decisions were issued or sanctions and imposed.
d. A statement of basis for the request for hearing.

3. Evidentiary Hearing
Upon receipt of the request for a State level hearing, a hearing before a designated hearing officer will be scheduled.

The hearing will be recorded mechanically or by court reporter.

Both parties concerned will have the opportunity to present oral and written testimony under oath, to call and question witnesses in support of his/her position, to present oral and/or written arguments, to examine records and documents relevant to the issue(s), and to be represented.

The hearing officer shall issue a written decision, which shall be forwarded to the State Review Panel for final determination.

The State Review Panel may accept, reject or modify this recommendation. The decision of the State Review Panel is final except for audit disallowances, which must be approved by the Secretary of Labor

C. State Review Panel

The State Review Panel will consist of a panel of three representatives from the Employment Development Department: one from the Legal Offices, one from the WID, and one from the Director’s office. The panel will issue a written decision, which will be sent to the appropriate parties within thirty (30) days of receipt of the request for State review.

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Decisions issued by this panel, under the authority of the Governor, are final.

D. Issuance of State Review Decision.

The State review will be limited to violations of the WIOA, implementing WIOA regulations or the grant agreement. This review shall be limited to the record established at the LWDA hearing.

V. Procedures for Handling Discrimination Complaints by Participants.

A. Complaints on the basis of race, color, or national origin, age, sex, religion, political affiliation or belief, retaliation, and citizenship, where appropriate, must be filed within 180 days of the alleged occurrence.

1. It is the responsibility of the Santa Ana LWDA’s Equal Employment Opportunity (EEO) Officer to determine jurisdiction and to make the complainant aware of and provide assistance in filing a complaint in accordance with the Santa Ana LWDA’s procedure under Section II (A).

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PROCEDURES FOR HANDLING NON-CRIMINAL COMPLAINTS

˚
˚
Informal Resolution Process
˚
˚
˚

˚
˚
˚
Unsatisfactory Decision or LWDA Decision not issued within 60 days ˚
˚
˚

˚
˚
˚
If no decision issued by State Review Panel
˚
˚
Appeal to DOL
60 Days

30 Days
30 Days

No later than
180 days of
alleged
discrimination
Handling of complaints filed at LWDA level arising in connection with WIOA programs operated by LWDAs
Filing of Complaint/Request for Hearing
Notice of Hearing issued by LWDA
Hearing Conducted
LWDA Decision within 60 days
Within 10 days of
receipt of
unsatisfactory
decision or 10
days from date
LWDA decision
should have been
issued.

Request for State Review
Governor’s Decision issued by State Review Panel
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2. In cases where areas of authority overlap, it is the responsibility of the EEO Officer to advise the complainant of the existence of State, Federal and other proper action agencies, which may also have a bearing.

3. Complainants alleging discrimination under this part will be made aware of their right to file directly with the Office of Civil Rights (OCR), U.S. Department of Labor and applicable procedures.

4. Complainants must file their complaint directly with:

Jennifer Sommers
Sr. Personnel Analyst – EEO Officer
20 Civic Center Drive, M-24
Santa Ana, CA 92701
(714) 647-5348

VI. Procedures for Handling Disability Complaints by Participants

Complaints alleging discrimination on the basis of disability will be filed and processed under the Department of Labor regulations implementing Section 504 of the Rehabilitation Act of 1973 at 29 Code of Federal Regulations Section 32.

1. Complaints must exhaust the Santa Ana LWDA’s informal resolution procedures before filing their complaint with OCR.

2. Complainants will be made aware of the 180 days requirement in which to file his/her complaint.

A. Procedures at the LWDA Level

1. The complainant shall file his/her complaint directly with the Santa Ana LWDA. Upon receipt of the complaint, the EEO Officer shall investigate and gather information concerning the complaint.

2. An informal conference will be held with the parties concerned in an effort to resolve the issue(s). The complainant has the right to be present and may be represented during the conference.

3. The Santa Ana LWDA shall issue in writing its decision to the complainant no later than thirty (30) days after the filing of the complaint.

B. Procedures at the State Level

1. The complainant may appeal to the State if he/she is not satisfied with the decision of the Santa Ana LWDA.

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2. The Complainant must file his/her appeal as a request for review directly with the Chief WID within ten (10) calendar days after the receipt of the Santa Ana LWDA’s decision.

3. The Chief-WID, shall issue a decision no later than thirty (30) calendar days after receipt of the request for review.

4. After the complainant has received a decision or no decision has been received from the Director of Employment Development Department (on behalf of the Governor), the complainant has the right to appeal his/her complaint within thirty (30) calendar days to the Office of Civil Rights (OCR) with the Department of Labor.

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PROCEDURES FOR HANDLING COMPLAINTS ON BASES OF DISABILITY

˚

˚
˚
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If no resolution reached
˚
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Unsatisfactory Decision or No Decision
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˚
˚

˚

No later than
180 days of
alleged
discrimination
Filing of complaint on the basis of Disability with LWDA Filed within 30
days of
LWDA/State
Decision or 90
days from date of
initial filing of
complaints
Informal Resolution

Request for Hearing
Notice of Hearing
Hearing Conducted
LWDA Decision
State Review
Governor’s Decision
Appeal to Assistant Secretary Department of Labor
Day 1
Day /45 Day
60 Days
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GLOSSARY OF WIOA TERM

AGE DISCRIMINATION ACT – A law passed by Congress in 1975 which prohibits discrimination on the basis of age by any program or activity receiving Federal Funds.

APPLICANT – An individual who applies to a subrecipient or contract for services provided under WIOA and who has not yet transitioned to the status of participant.

ASSESSMENT – Services designed to determine each participant’s employability, aptitudes, abilities and interests and to develop a plan to achieve the participant’s employment and related goals; also to identify the available employment and traning activities appropriate for the participant. Testing and counseling may also be used during assessment process.

CHARGING PARTY (CP), COMPLAINANT, GRIEVANT, OR AGGRIEVED PERSON – The person who charges that he/she has been discriminated against under Department of Justice nondiscrimination and civil rights regulations and/or guidelines.

DISCRIMINATION – In general, a failure to treat all equally, whether intentional or unintentional; the effect of an action, policy or practice which selects an individual or class of persons to receive unequal treatment.

ELIGIBLE NON-CITIZEN – Lawfully admitted permanent resident, aliens, lawfully admitted refugees, and parolees and other individuals authorized by the Attorney General to work in the United States.

EMPLOYER – An employer subject to the p rovisions of the Civil Rights Act of 1964, as amended, including state and local governments and any Federal agency subjects to the provisions of Section 717 of the Civil Rights Act, as amended; and any Federal contractor or subcontractor covered by executive Order 11246, as amended.

GRIEVANCE – An allegation that something imposes an illegal obligation or burden or denies some equitable or legal right, or causes injustice .

INDIVIDUAL WITH A DISABILITY – Any individual who has a physical or mental disab ility that constitutes or results in a substantial challenge to employment.

INTAKE – Includes screening to determine eligibility; to select from eligible applicants those individuals who are most in need and can benefit from program services; to complete procedural requirements necessary to enroll an individual into the program and to refer those not enrolled to other programs.

JOINT COMPLAINT – A complaint of employment discrimination covered by Title VII or the Equal Pay Act and by Title VI or Title IX. Individual “joint complaints” are normally investigated by EEOC unless OCR has a compelling reason to investigate. “Joint complaints” alleging discrimination in employment and other practices and pattern or practice “joint complaints” are normally inves tigated by OCR.

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JURISDICTION – Authority to investigate and resolve complaints against an institution subject to a law or statute which has been assigned to OCR for enforcement, i.e., Title VI, Title IX, etc.

PARTICIPANT – Any applicant who has: (1) Been determined eligible for participation upon intake; and (2) Who is receiving subsidized employment, training or services (except post -termination services) funded under the Act, following intake, except for an individual who receives only outreach and/or intake and assessment services.

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Trainee Handbook revised 10/2023 27

GRIEVANCE POLICY

If you believe Hope Builders has violated your rights, treated you unfairly or discriminatory in any manner, you have the right to appeal the decision. Appeals can be voiced to the appropriate staff member listed below via telephone and/or through a written complaint at:

Hope Builders
801 N. Broadway
Santa Ana, California 92701
Hope Builders will not retaliate against you in any way should you choose to file a complaint.

Amber Rizkalla, Director of Programs
[email protected]
714-543-5105 Ext: 136

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Exhibit D

Hope Builders Budget Narrative

Total Program Cost: Total program cost is $1,461,112, which represents the full cost of delivering all program services, instruction, supportive services, and operational activities across all funding sources.

Total WIOA Allocation: Total WIOA allocation is $200,000, which supports a portion of direct program implementation, instructional staffing, and participant services within the overall program model.

Match/In-Kind: Total match/in-kind is $1,261,112, which represents leveraged funding and contributed resources that significantly expand program capacity and support full service delivery beyond the WIOA investment.

Summary of Personnel Salaries & Benefits: Total WIOA budget is $146,168, which supports instructional staff and program personnel responsible for delivering direct training and workforce preparation services across all program components.

Operating Expenses: Total is $53,832, which covers program-related costs such as supportive services, participant incentives, and other direct program supports that enable participant success and retention.

Indirect Cost/Administrative Cost: Total is $21,925, which represents 15% of allowable Personnel Salaries and Benefits costs in accordance with the approved indirect cost limitation.

Indirect costs are applied only to eligible staff salary and benefit expenses and are not calculated against the total program budget.

WEX Allocation: Total WEX allocation is $151,687, which includes Personnel Salaries & Benefits ($129,687) for staff directly supporting Work Experience (WEX) and workforce preparation activities, as well as Participant Stipends ($22,000) that provide weekly $100 stipends to participants engaged in structured work-based learning activities. The WEX allocation demonstrates a strong emphasis on direct training, work-based learning, and participant workforce preparation activities.

Personnel Salaries: These personnel provide direct instruction and hands-on training to participants across program areas, ensuring the delivery of job-ready skills and structured learning experiences aligned with industry standards.

Clinical Medical Assisting (CMA) Instructor—Sofia Diaz; 21% FTE for 12 months; $15,565 salary.

Sofia Diaz will deliver hands-on instruction and skills training for participants in the CMA program. She will teach core clinical competencies, support skill development through guided practice, and provide individualized feedback to help participants build confidence and proficiency for employment in the healthcare field. Her role is essential in preparing youth with practical, job-ready skills that increase their employability.

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Exhibit D

Clinical Medical Assisting (CMA) Instructor—Manara McCobb; 21% FTE for 12 months; $16,291 salary. Manara McCobb will deliver hands-on instruction and skills training for participants in the CMA program. She will teach core clinical competencies, support skill development through guided practice, and provide individualized feedback to help participants build confidence and proficiency for employment in the healthcare field. Her role is essential in preparing youth with practical, job-ready skills that increase their employability.

Child Development Careers (CDC) Instructor—Lauren Eddy; 21% FTE for 12 months; $16,800 salary. Lauren Eddy will deliver hands-on instruction and skills training for participants in the CDC program. She will teach foundational child development concepts, facilitate applied learning activities, and provide individualized support to help participants develop the skills needed for careers working with children. Her role is essential in preparing youth with practical, job-ready skills that increase their employability.

Construction Training Program (CTP) Instructor—Michael O’Neill; 21% FTE for 12 months; $15,750 salary. Michael O’Neill will deliver hands-on instruction and skills training for participants in the CTP program. He will teach construction fundamentals, guide participants through practical, tool-based learning, and provide individualized feedback to build competency and confidence in the trades. His role is essential in preparing youth with practical, job-ready skills that increase their employability.

Admissions Lead—Erika Rios-Streitz, 21% FTE for 12 months; $15,120 salary. Erika Rios-Streitz will manage the admissions process, ensuring the smooth intake of eligible participants into the program. She will support youth in navigating the application process, ensuring that they meet program requirements and receive appropriate support. Her role supports the grant by ensuring that qualified participants are recruited, contributing to the program’s overall success.

Employment Readiness Lead—Cindy Mendizabal, 21% FTE for 12 months; $15,750 salary. Cindy Mendizabal will oversee the employment readiness activities of the program. She will coordinate job preparation workshops, resume writing, and interview coaching to ensure that participants are fully equipped for employment. Her role directly impacts the success of the program by improving the employability of youth participants.

Employment Readiness Specialist—Sabine Shah, 21% FTE ($13,374) for 12 months; $14,362 salary. Sabine Shah will provide direct support services to program participants. She will assist participants with accessing resources, offer guidance, and ensure that they stay on track to achieve their career readiness goals. Her role is critical in ensuring that participants receive the necessary support to succeed throughout their training and transition into employment.

Employment Readiness Coordinator—Julia Montgomery, 21% FTE ($55,162) for 12 months; $12,230 salary. Julia Montgomery will provide employment readiness training to participants.

She will assist participants with job search activities, resume development, and interview EXHIBIT 3

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Exhibit D

preparation. Her role is essential in ensuring that participants are fully equipped with the skills and resources needed to successfully transition into employment.

Employment Readiness Coordinator—Blanca Valenzuela, 21% FTE ($55,162) for 12 months; $12,230 salary. Blanca Valenzuela will provide employment readiness training to participants.

She will assist participants with job search activities, resume development, and interview preparation. Her role is essential in ensuring that participants are fully equipped with the skills and resources needed to successfully transition into employment.

Personnel Benefits: These costs reflect employer-required payroll taxes associated with instructional staff, including Social Security, Medicare, and state employer taxes that support compliance with federal and state employment requirements.

Clinical Medical Assisting (CMA) Instructor—Sofia Diaz: 9% benefits of $15,770 salary: $1,401 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

Clinical Medical Assisting (CMA) Instructor—Manara McCobb: 9% benefits of $17,152 salary:
$1,466 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

Child Development Careers (CDC) Instructor—Lauren Eddy: 9% benefits of $15,310 salary:
$1,512 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

Construction Training Program (CTP) Instructor—Michael O’Neill: 9% benefits of $16,072 salary:
$1,418 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

Admissions Lead—Erika Rios-Streitz: 9% benefits of $13,461 salary: $1,361 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

Employment Readiness Lead—Cindy Mendizabal: 9% benefits of $15,440 salary: $1,418 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

Employment Readiness Specialist—Sabine Shah: 9% benefits of $13,374 salary: $1,293 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

Employment Readiness Coordinator—Julia Montgomery: 9% benefits of $11,603 salary: $1,101 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

EXHIBIT 3

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Exhibit D

Employment Readiness Coordinator—Blanca Valenzuela: 9% benefits of $11,603 salary: $1,101 for Benefits (6.2% Fed Social Security Tax, 1.45% Fed Medicare Tax, and 1.35% State Employer Taxes)

Operating Expenses: These costs represent facility and operational categories that support program delivery; however, no funds are allocated in these areas for this project.

Rent: $0 - No rent costs are allocated to this project.

Utilities: $0 - No utility costs are allocated to this project.

Phones: $0 - No phone costs are allocated to this project.

Internet Fees: $0 - No internet costs are allocated to this project.

Parking Fees: $0 - No parking costs are allocated to this project.

Security: $0 - No security costs are allocated to this project.

Maintenance: $0 - No maintenance costs are allocated to this project.

Insurance: $0 - No insurance costs are allocated to this project.

Equipment Rental Fees: $0 - No equipment rental costs are allocated to this project.

Vehicle Lease: $0 - No vehicle lease costs are allocated to this project.

Office Expenses (Consumables): $0 - No office consumable costs are allocated to this project.

Accounting Services: $0 - No accounting service costs are allocated to this project.

Legal Services: $0 - No legal service costs are allocated to this project.

Auditing Services: $0 - No auditing service costs are allocated to this project.

Indirect Cost: $21,925 for administrative costs that support overall program operations, including organizational oversight, compliance, and general administrative functions.

Staff Training: $0 - No staff training costs are allocated to this project.

Staff Conferences: $0 - No staff conference costs are allocated to this project.

Staff Travel/Mileage: $0 - No staff travel or mileage costs are allocated to this project.

EXHIBIT 3

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Exhibit D

Participant Wages: $22,000 - Provides weekly $100 stipends to participants engaged in Work Experience (WEX) activities. These payments are treated as participant compensation for participation in structured work-based learning placements and are reported under participant wages in accordance with program and budget guidelines.

Supportive Services: $9,907 Supportive Services cover essential materials, equipment, certifications, and supplies needed for participants in the CMA, CDC, and CTP programs to fully engage in training. These include industry-specific textbooks and tools, uniforms and safety gear, certification and testing costs, transportation and childcare assistance, drug and background testing, and general classroom and learning supplies that support successful program completion.

Participant Incentives: $0 - No participant incentive costs are allocated to this project.

Youth Conferences: $0 - No youth conference costs are allocated to this project.

IT Expenses: $0 - No IT costs are allocated to this project.

Program Supplies: $0 - No program supply costs are allocated to this project.

EXHIBIT 3

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Budget Form
Hope Builders
Administrative
Cost (Not to
Exceed 15%)
Total
Program
Cost
Total WIA Cost Match/In Kind
CMA Instructor $74,118 $15,565 $58,553
CMA Instructor $77,577 $16,291 $61,286
CDC Instructor $80,000 $16,800 $63,200
CTP Instructor $75,000 $15,750 $59,250
Admissions Lead $72,000 $15,120 $56,880
Employment Readiness Lead $75,000 $15,750 $59,250
Employment Readiness Specialist $68,390 $14,363 $54,027 Employment Readiness Coord. $58,240 $12,230 $46,010
Employment Readiness Coord. $58,240 $12,230 $46,010
CMA Instructor $18,530 $1,401 $17,129
CMA Instructor $19,394 $1,466 $17,928
CDC Instructor $20,000 $1,512 $18,488
CTP Instructor $18,750 $1,418 $17,333
Admissions Lead $18,000 $1,361 $16,639
Employment Readiness Lead $18,750 $1,418 $17,333
Employment Readiness Specialist $17,098 $1,293 $15,805
Employment Readiness Coord. $14,560 $1,101 $13,459
Employment Readiness Coord. $14,560 $1,101 $13,459
Total Personnel Salaries & Benefits $798,207 $146,168 $652,039 Rent $138,168 $0 $138,168
Utilities $7,200 $0 $7,200
Phones
Internet Fees $9,360 $0 $9,360
Parking Fees
Security
Maintenance
Insurance $3,996 $0 $3,996
Equipment rental fees*
Equipment rental fees*
Vehicle lease*
Office expenses (consumables)
Accounting Services
Legal Services
Auditing Services
Indirect Cost* $21,925 $21,925 $0
Staff Training
Staff Conferences
Staff Travel/Mileage
Participant Wages* $22,000 $22,000 $0
Supportive Services* $9,907 $9,907 $0
Participant Incentives*
Youth Conferences
IT Expenses $54,000 $0.00 $54,000
Program Supplies $298,543 $0.00 $298,543
Total Operating Expenses $0 $565,099 $53,832 $511,267
GRAND TOTAL (Personnel + Operating) $0.00 $1,363,306 $200,000 $1,163,306 Personnel Salaries
Personnel Benefits
Operating Expenses

EXHIBIT D
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Budget Form
Hope Builders

Personnel

OPERATING EXPENSES
Salaries: List each individual position dedicated to this project. List title, percentage of full time equivalent (FTE) or the amount of time to be charged to this project.

Budget Form Instructions for YSPN Membership
All costs related to the program activities described in the proposal must be included on the Budget Form. A budget narrative must be attached on a separate sheet of paper for all line items marked with an * asterisk.

Support Services: Attach policies and procedures for supportive services. Policy must include spending limits.

Participant Incentives: Indicate the type of payment, rate of payment and describe what youth must achieve to receive the incentive.

Other: This item may include fieldtrips and youth stipends. All items must listed and include cost details.

States, local governments and non-profit institutions who receive $500,000 or more in federal funds in a fiscal year shall meet the audit requirements of the OMB Circular A-133, “Audits of States, and Local Governments Benefits: List each individual position dedicated to this project. List title, percentage of full time equivalent (FTE) or the amount of time to be charged to this project.

Rent or User Fee: Provide percent of office space that will be charged to this project. Describe how percentage was determined.

Equipment Rental Fee (equipment may not be purchased): List items that will be used for this project.

Provide percent of rental fee that will be charged to this project. Describe how percentage was determined.

Vehicle Lease (vehicles may not be purchased): Provide list of vehicles dedicated for this project. Describe vehicle use and percentage of use that will be charged to this project. Describe how percentage was Indirect Cost: Provide indirect cost rate plan.

Participant Wages: Describe costs directly related to individual participants such as paid training and/or work experience. Include number of youth, hourly wage, benefits and bonuses. Include length of activity.

EXHIBIT D
EXHIBIT 3

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CITY OF SANTA ANA
The undersigned certifies, to the best of his or her knowledge and belief, that:
1) No Federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, to any person for influencing or attempting to influence an officer or employee of any organization, a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement.
2) If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any organization, a Member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with this Federal contract, grant, loan, or cooperative agreement, the undersigned shall complete and submit Standard Form-LLL, ‘‘Disclosure Form to Report Lobbying.’’ in accordance with its instructions.
3) The undersigned shall require that the language of this certification be included in the award documents for all subawards at all tiers (including agreements) and that all subrecipient’s shall certify and disclose accordingly.

This certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into. Submission of this certification is a prerequisite for making or entering into this transaction imposed by 31 U.S.C. 1352.

Any person who fails to file the required certification shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such failure occurring on or before October 23, 1996, and of not less than $11,000 and not more than $110,000 for each such failure. ___________________
Grantee/Contractor Organization
Signature Date

____________________
Name of Certifying Official Signature

CERTIFICATION REGARDING LOBBYING

Exhibit E
Taller San Jose Hope Builders
Shawna Smith
03/16/26
EXHIBIT 3

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Certification Regarding Drug-Free Workplace Requirements The certification set out below is a material representation upon which reliance is placed by the U.S. Department of Housing and Urban Development in awarding the grant. If it is later determined that the contractor knowingly rendered a false certification, or otherwise violates the requirements of the Drug-Free Workplace Act, the U.S.

Department of Housing and Urban Development, in addition to any other remedies available to the Federal Government, may take action authorized under the Drug-Free Workplace Act
.

CERTIFICATION
A. The contractor certifies that it will provide a drug-free workplace by:
(a) Publishing a statement notifying employees that the unlawful manufacture, distribution, dispensing, possession or use of a controlled substance is prohibited in the contractor’s workplace and specifying the actions that will be taken against employees for violation of such prohibition; (b) Establishing a drug-free awareness program to inform employees about – (1) The dangers of drug abuse in the workplace;
(2) The contractor’s policy of maintaining a drug-free workplace; (3) Any available drug counseling, rehabilitation, and employee assistance program; and
(4) The penalties that may be imposed upon employees for drug abuse violations occurring in the workplace;
(c) Making it a requirement that each employee who will be engaged in the performance of the grant be given a copy of the statement required by paragraph (a);
(d) Notifying the employee in the statement required by paragraph - (a) that, as a condition of employment under the contract, the employee will - (1) Abide by the terms of the statement; and
(2) Notify the employer of any criminal drug statute conviction for a violation occurring in the workplace no later than five days after such conviction.
(e) Notifying the U.S. Department of Housing and Urban Development within ten days after receiving notice under subparagraph (d)(2) from an employee or otherwise receiving actual notice of such conviction; EXHIBIT 3

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(f) Taking one of the following actions, within 30 days of receiving notice under subparagraph (d)(2), with respect to any employee who is so convicted -
( 1) Taking appropriate personnel action against such an employee, up to and including termination; or
(2) Requiring such employee to participate satisfactorily in a drug abuse assistance or rehabilitation program approved for such purposes by a Federal, State, or local health, law enforcement, or other appropriate agency;
(g) Making a good faith effort to continue to maintain a drug-free workplace through implementation of paragraphs (a), (b), (c), (d), (e) and (f).

B. The contractor shall insert in the space provided on the attached “Place of Performance” form the site(s) for the performance of work to be carried out with the grant funds (including street address, city, county, state, and zip code) .the contractor further certifies that, if it is subsequently determined that additional sites will be used for the performance of work under the contract, it shall notify the U.S. Department of Housing and Urban Development immediately upon the decision to use such additional sites by submitting a revised “Place of Performance” form.

Organization
Authorized Signature Date

EXHIBIT F
EXHIBIT 3

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PLACE OF PERFORMANCE

FOR CERTIFICATION REGARDING DRUG-FREE

WORKPLACE REQUIREMENTS
Name:

Date:

The Contractor shall insert in the space provided below the site(s) expected to be used for the performance of work under the contract covered by the certification:

Place of Performance (include street address, city, county, state, zip code for each site):

EXHIBIT 3

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CITY OF SANTA ANA
This certification is required by the regulations implementing Executive Order 12549, Debarment and Suspension, 29 CFR Part 98, Section 98.510, Participants' Responsibilities. The regulations were published as Part VII of the May 16, 1988, Federal Register (Pages 19160-19211). (Before completing certification, read instructions which are an integral part of certification)

1. The prospective primary participant, (i.e. grantee) certifies to the best of its knowledge and belief, that it and its principals:
a. Are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from covered transactions by any federal department or organization; b. Have not within a three-year period preceding this proposal been convicted or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public (federal, state or local) transaction or contract under a public transaction; violation of federal or state antitrust statues or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen property.
c. Are not presently indicted for or otherwise criminally or civilly charged by a government entity (federal, state or local) with commission of any of the offenses enumerated in paragraph (1)(b) of this certification; and
d. Have not within a three-year period preceding this application/proposal had one or more public transactions (federal, state or local) terminated for cause or default.

2. Where the prospective primary participant is unable to certify to any of the statements in this certification, such prospective participant shall attach an explanation to this proposal.

CERTIFICATION REGARDING DEBARMENT
Taller San Jose Hope Builders_______________________________________ Grantee/Contractor Organization
Shawna Smith, Executive Director_______________________________________ Name and Title of Official Authorized to Certify
On Behalf of the Grantee
03/16/2026 ______________________________________
Date

EXHIBIT G
EXHIBIT 3

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CITY OF SANTA ANA

SIGNATURES & ASSURANCES
The assurances are:

1. I am authorized by my Board of Directors, Trustees, or other legally qualified officer to submit this proposal on behalf of the “Applicant.”

2. Applicant is not currently on any federal, State of California or local Debarment List.

3. Applicant will provide records to show fiscal solvency, if required.

4. Applicant will meet all applicable Federal, State and local compliance and regulatory requirements.

These include but are not limited to
a. Ensuring that records accurately reflect actual performance; b. Maintaining record confidentiality, as required;
c. Reporting financial participant, and performance data, as required; d. Meeting requirements of Section 504 or the Rehabilitation Act of 1973; e. Meeting all applicable labor laws, including Child Labor Law standards; and f. Meeting all lobbying certification and disclosure of lobbying activities requirements.

5. Applicant will establish, in accordance with section 184 of the Workforce Innovation & Opportunity Act, fiscal control and fund accounting procedures necessary to ensure the proper disbursement of, and accounting for funds provided to the Local Workforce Development Board.

6. That it will comply with the uniform administrative requirements referred to in WIOA.

7. Compliance with the confidentiality requirements of WIOA.

8. That no funds received under the Workforce Innovation & Opportunity Act will be used to assist, promote or deter union organizing.

9. That it will comply with the nondiscrimination provisions of WIOA, including an assurance that Methods of Administration have been developed and implemented.

10. That it will collect and maintain data necessary to show compliance with the nondiscrimination provisions of WIOA.

11. That there will be compliance with grant procedures of WIOA.

12. That all funds will be spent in accordance with the Workforce Innovation & Opportunity Act, written Department of Labor guidance, and other applicable Federal and State laws and regulations.

13. That it will endeavor to partner and plan with such entities, that the SAWDB, its subcommittees or staff direct, including regionally, statewide or nationally.

14. That it will comply with such new regulations that are set forth in the new Law that will govern the activities set forth herein.

15. That it will comply with new policies initiated by the State of California, City of Santa Ana, as appropriate.

16. Respondent will not:
a. Place a costumer in a position that will displace a current employee; b. Use WIOA money to assist, promote, or deter union organizing; c. Use funds to employ to train persons in sectarian activities; and d. Use funds for customers in the construction, operation, or maintenance of any part of a facility to be used for sectarian instruction or religious worship.

SIGNATURES & ASSURANCES
I recognize that I must give assurance for each item above, 1 through 16, as applicable. If I cannot, this proposal will be automatically rejected.
(Signature required)
COMMENTS:

EXHIBIT H
EXHIBIT 3

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CITY OF SANTA ANA
Instructions: Please complete this form, sign and submit to the Santa Ana Workforce Investment Board.

Subrecipient
Agreement Date
Agreement Amount
SAM.gov UEI #_______________________________

Catalog of Federal Domestic Assistance (CFDA)
The Catalog of Federal Domestic Assistance (CFDA) is a government-wide compendium of Federal programs, projects, services, and activities that provide assistance or benefits to the American public.

It contains financial and nonfinancial assistance programs administered by departments and establishments of the Federal government. The primary purpose is to assist users in identifying programs that meet specific objectives (for more information refer to:
https://sam.gov/content/assistance-listings )
CFDA Title & Number: WIOA Youth Activities #17.259
______ initial if you understand and agree with the above statement

Monitoring
Subrecipient will or may be monitored by officials from the City, State, or Federal entities. Monitoring may include the review of the subrecipient’s use of Federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved.
______ initial if you understand and agree with the above statement

Audits
Subrecipients expending $750,000 or more in Federal awards during the fiscal year must have met the audit requirements of OMB Super Circular section 200.501 within 9 months of the end of the subrecipients audit period (refer to:
https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part- 200/subpart-F ).

Please provide documentation that demonstrates the most recent audit in compliance with the above mentioned OMB Circular or a letter indicating why you didn’t require a single audit for PY 2024. □ See Attached □Not Applicable
______ initial if you understand and agree with the above statement

SUBRECIPIENT COMPLIANCE FORM
Taller San Jose Hope Builders
03/16/2026
$200,000
SYUWJWBCZKU3
03/16/2026
EXHIBIT 3

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CITY OF SANTA ANA
I. Is there a minimum of 2 designated disabled parking slots? Per Dept. of Rehab Sect. 504 YES NO
II. Are individuals able to reach the building’s entrance for individuals with a disability without having to go behind any other cars, or any other barriers (curb, sidewalks, etc.).

Per Dept. of Rehab. Sect. 504 YES NO
III. Is there a front door labeled with the international wheelchair access sign? Per Dept. of Rehab. Sect. 504 YES NO
Is the labeled entrance’s threshold not higher than ½ inch to allow for wheelchair access? Per Dept. of Rehab. Sect. 504 YES NO
IV. Is the door-handle to the labeled wheelchair entrance door, a lever handle (not a round doorknob)?
Per Dept. of Rehab. Sect. 504 YES NO
V. If any services are available on the second floor, does the building have an elevator? Per Dept. of Rehab. Section 504 YES NO NA
VI. Does the classroom, working area, and break-room have enough room to maneuver a wheelchair and/or crutches?
Per Dept. of Rehab. Sect. 504 YES NO
VII. Does the provider catalog / employee manual, contain the organization’s Grievance Policy? Per WIOA Section 188 & 29 CFR Part 38 YES NO
VIII.I s Grievance Procedure and contact person made available in writing to the participant on or before the first day of program participation.

Per WIOA Section 188 & 29 CFR Part 38 YES NO
IX. If serving any Limited English individuals is the grievance procedure and procedures available in their language.

Per Title 29 CFR Section 38.36(b) YES NO
X. Is there at least one internationally labeled accessible restroom for the disabled.

Per Dept. of Rehab. Sect. 504 YES NO

AMERICANS WITH DISABILITY ACT (ADA) AND EQUAL OPPORTUNITY (EO) LAW SURVEY
EXHIBIT 3

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CITY OF SANTA ANA
XI. Does toilet stall for individuals with a disability have bars on each side of the wall.

Per Dept. of Rehab. Sect. 504 YES NO
XII. Is there a telephone reasonably accessible to individuals with a disability? Per Dept. of Rehab. Sect. 504 YES NO
XIII. Is there a water fountain reasonably accessible to individuals with a disability? Per Dept. of Rehab. Sect. 504 YES NO
XIV. Are auxiliary (supplementary) aides available when requested by the individual.

Per CFR Title 20,29,41 YES NO
Youth Service Provider Information:

Print First & Last Name
Service Provider Signature Date

Business Address

Business Phone Number
All information is subject to validation by SAWDB staff upon approval of award.

Shawna Smith
03 / 1 6 / 2 6
801 N Broadway, Santa Ana, CA 92701
714-543-5105
EXHIBIT 3

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SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.

INSURER(S) AFFORDING COVERAGE
INSURER F :

INSURER E :

INSURER D :

INSURER C :

INSURER B :

INSURER A :

NAIC #
NAME:

CONTACT
(A/C, No):

FAX
E-MAIL
ADDRESS:

PRODUCER
(A/C, No, Ext):

PHONE

INSURED
REVISION NUMBER:CERTIFICATE NUMBER:COVERAGES
IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

OTHER:
(Per accident)
(Ea accident)
$
$
N / A
SUBR
WVD
ADDL
INSD

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS

CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. $ $
$
$PROPERTY DAMAGE
BODILY INJURY (Per accident)
BODILY INJURY (Per person)

COMBINED SINGLE LIMIT

AUTOS ONLY

AUTOSAUTOS ONLY

NON-OWNED

SCHEDULEDOWNED

ANY AUTO

AUTOMOBILE LIABILITY
Y / N

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY
OFFICER/MEMBER EXCLUDED?
(Mandatory in NH)
DESCRIPTION OF OPERATIONS below
If yes, describe under

ANY PROPRIETOR/PARTNER/EXECUTIVE
$
$
$
E.L. DISEASE - POLICY LIMIT
E.L. DISEASE - EA EMPLOYEE
E.L. EACH ACCIDENT
ER
OTH-

STATUTE
PER

LIMITS(MM/DD/YYYY)

POLICY EXP
(MM/DD/YYYY)

POLICY EFF

POLICY NUMBERTYPE OF INSURANCELTR
INSR
DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

EXCESS LIAB
UMBRELLA LIAB $EACH OCCURRENCE
$AGGREGATE
$
OCCUR

CLAIMS-MADE
DED RETENTION $
$PRODUCTS - COMP/OP AGG
$GENERAL AGGREGATE
$PERSONAL & ADV INJURY
$MED EXP (Any one person)
$EACH OCCURRENCE

DAMAGE TO RENTED
$PREMISES (Ea occurrence)

COMMERCIAL GENERAL LIABILITY

CLAIMS-MADE OCCUR
GEN'L AGGREGATE LIMIT APPLIES PER:

POLICY PRO-

JECT LOC

CERTIFICATE OF LIABILITY INSURANCE

DATE (MM/DD/YYYY)

CANCELLATION

AUTHORIZED REPRESENTATIVE
ACORD 25 (2016/03)
© 1988-2015 ACORD CORPORATION. All rights reserved.

CERTIFICATE HOLDER
The ACORD name and logo are registered marks of ACORD
HIRED

AUTOS ONLY
4/22/2026
Patriot Growth Insurance Services, LLC
7777 Center Avenue, Suite 600
Huntington Beach CA 92647
Julie Doan
714-733-6200
[email protected]
Nonprofits' Insurance Alliance of California
11384
TALLSAN-01
QBE Insurance Corp/ The ILM Group
Taller San Jose Hope Builders dba Hope Builders
Hope Builders Career Connections
801 N Broadway
Santa Ana CA 92701
Philadelphia Indemnity Insurance
18058
Cornerstone Insurance Plc
2093043825
A
X
1,000,000
X
500,000
20,000
1,000,000
2,000,000
X
X
Prof. Liability
Y
Y
20236888
10/1/2025
10/1/2026
2,000,000
Aggregate
$2,000,000
C
1,000,000
X
X
X
Y
Y
PHPK2606749
10/1/2025
10/1/2026
A
X
X
2,000,000
202368880UMB
10/1/2025
Y
10/1/2026
D
X
Y
WC04400336024
9/1/2025
9/1/2026
1,000,000
1,000,000
1,000,000
B
A
C
Accident/Sexual Misconduct
Social Service Professional Liab
Crime
MHH010307/20226880ACC
20236888
PHPK2606749
10/1/2025
10/1/2025
10/1/2025
10/1/2026
10/1/2026
10/1/2026
Aggregate
Per Event/Aggregate
Aggregate
$1,000,000
$2mm/$2mm
$250,0000
RE: 100 N Harbor Blvd., Ste 200, Anaheim CA 92805
City of Santa Ana, its City Council, officers, officials, employees, agents, and volunteers are named as additional insured with respects to General liability, auto liability. Policies are primary and non-contributory. Waiver or subrogation applies.

City of Santa Ana
20 Civic Center Plaza
Santa Ana CA 92701
EXHIBIT 3

City Council
15 –
382
6/16/2026

COMMERCIAL GENERAL LIABILITY
THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY.

ADDITIONAL INSURED – DESIGNATED

PERSON OR ORGANIZATION
CG 20 26 12 19Taller San Jose Hope Builders dba: Hope buildersNamed Insured:

Any person or organization that you are required to add as an additional insured on this policy, under a written contract or agreement currently in effect, or becoming effective during the term of this policy. The additional insured status will not be afforded with respect to liability arising out of or related to your activities as a real estate manager for that person or organization.

Name Of Additional Insured Person(s) Or Organization(s):

SCHEDULE

COMMERCIAL GENERAL LIABILITY COVERAGE PART
This endorsement modifies insurance provided under the following:

Information required to complete this Schedule, if not shown above, will be shown in the Declarations.

Section II – Who Is An Insured is amended to
include as an additional insured the person(s) or
organization(s) shown in the Schedule, but only
with respect to liability for "bodily injury", "property damage" or "personal and advertising injury"
caused, in whole or in part, by your acts or
omissions or the acts or omissions of those acting
on your behalf:

1. In the performance of your ongoing operations;
or

2. In connection with your premises owned by or
rented to you.

However:

1. The insurance afforded to such additional
insured only applies to the extent permitted by
law; and

2. If coverage provided to the additional insured is
required by a contract or agreement, the
insurance afforded to such additional insured
will not be broader than that which you are
required by the contract or agreement to
provide for such additional insured.

B.A. With respect to the insurance afforded to these
additional insureds, the following is added to
Section III – Limits Of Insurance:

If coverage provided to the additional insured is
required by a contract or agreement, the most we
will pay on behalf of the additional insured is the
amount of insurance:

1. Required by the contract or agreement; or

2. Available under the applicable Limits of
Insurance shown in the Declarations;
whichever is less.

This endorsement shall not increase the
applicable Limits of Insurance shown in the
Declarations.

Page 1 of 1 ends
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