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
§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
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
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.
EXHIBIT 2
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
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
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
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.
EXHIBIT 2
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:
EXHIBIT 2
(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
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:
EXHIBIT 2
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
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
(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
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
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.
They will be connected to WIOA-approved education and training programs in these high- EXHIBIT 2
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
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
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.
Clients may also request to utilize the Job Search Lab located at the Career Success Center to access the computers and resource library. The Career Navigator will conduct quarterly check- EXHIBIT 2
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
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
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
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
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
• 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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2 EXHIBIT C
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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3 EXHIBIT C
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
7 EXHIBIT C
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
˚
˚
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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˚
˚
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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
EXHIBIT 2
20 EXHIBIT C
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.
EXHIBIT 2
21 EXHIBIT C
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.
EXHIBIT 2
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.
EXHIBIT 2
ATTACHMENT I - BUDGET NARRATIVE
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
ATTACHMENT I - BUDGET NARRATIVE
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
ATTACHMENT I - BUDGET NARRATIVE
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
EXHIBIT 2
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
ATTACHMENT I - BUDGET NARRATIVE
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.
EXHIBIT 2
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
EXHIBIT 2
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
EXHIBIT 2
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
EXHIBIT 2
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
EXHIBIT 2
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
EXHIBIT 2
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
(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
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
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
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
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
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
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
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
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
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
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
EXHIBIT 2