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Ie: Chief Execi e Officer and Director AFFIRMATIVE ACTION PLAN FOR MINORITIES AND WOMEN Planetary Science Institute E. Ft. Lowell Road, Suite 106 Tucson, AZ 85719 For Plan Year February 1, 2013 to January 31, 2014 Pl an prepared by: Li nda Rueger Title : Human Resources Specialist Phone: 520-382-0594 Signature: / Plan approved by: Mark V. Sykes, Ph .D., J.D. Signature: Facility: D&B # 94771068 EIN # 33-0175263 EEO-1 # N/A SIC 541710

~l.t?~ - Planetary Science Institute Minorities and...PSI AAP 2013 Page 5 PRIOR YEAR’S AAP AND PERFORMANCE Summary of Prior Year’s Affirmative Action Plan – Demonstration of

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Ie: Chief Execi e Officer and Director

AFFIRMATIVE ACTION

PLAN FOR

MINORITIES AND

WOMEN

Planetary Science Institute

1'~00 E. Ft. Lowell Road, Suite 106

Tucson, AZ 85719

For Plan Year

February 1, 2013 to January 31, 2014

Plan prepared by: Linda Rueger

Title : Human Resources Specialist Phone: 520-382-0594

Signature: ~l.t?~ /

Plan approved by: Mark V. Sykes, Ph .D., J.D.

Signature: ---J:'-~~~~'d+::lf------~-----

Facility:

D&B # 94771068

EIN # 33-0175263

EEO-1 # N/A

SIC 541710

PSI AAP 2013 Page 2

Table of Contents Page

Company History 3 Designation of Responsibility for Implementation of the AAP 4 Prior Year’s AAP and Performance 5 Branch Locations 6 Introduction to AAP 7 AAP Elements a. Organizational Profile 8 b. Job Group Analysis 9 - 11 c. Determination of Availability and Comparisons of Incumbency to Availability 12 - 15 d. Set Placement Goals 16 - 18 e. Statement Regarding Reasonable Recruitment Area 19 Review of Common Potential Problem Areas of Total Employment Process and Internal Audit and Reporting Systems 20 - 24 Compliance with Equal Pay Act and Compensation Systems Analysis 25 - 27 Development and Execution of Action-Oriented Programs 28 Documentation of Compliance – Corporate Management Compliance Evaluation 29 Equal Employment Policy 30 Anti-Sexual Harassment Policy 31 Compliance with Sex Discrimination Guidelines 32 Dissemination of the Affirmative Action Policy 33 Recruitment Letter 34 Record Retention Requirements 35 Definition of Applicant and Applicant Log 36 Glossary of Terms 37

PSI AAP 2013 Page 3

COMPANY HISTORY

The Planetary Science Institute (“PSI”) is a nonprofit, scientific research and educational corporation, incorporated in Arizona, designated as a 501(c)(3) tax-exempt organization by the United States Internal Revenue Service. PSI was originally formed in Tucson, Arizona, in 1972. In 2012, PSI had more than 100 employees, including scientists with a Ph.D. in nineteen (19) states.

PSI AAP 2013 Page 4

DESIGNATION OF RESPONSIBILITY FOR IMPLEMENTATION OF AFFIRMATIVE ACTION PLAN (“AAP” OR “PLAN”)

Mark Sykes, Chief Executive Officer and Director, has the ultimate responsibility for ensuring that equal employment opportunity and affirmative action receive the high level of priority that is due this activity. Linda Rueger has been designated as the Equal Employment Opportunity/Affirmative Action Administrator of PSI and has the full support of Dr. Sykes and other top management in carrying out these duties. PSI considers its staff to be its most valuable asset. Its philosophy and policy on equal employment opportunity and affirmative action is set out in its corporate employment policy and in its personnel policy handbook. Ms. Rueger’s responsibilities as Equal Employment Opportunity/Affirmative Action Administrator include the following:

Write the Affirmative Action Plan (“AAP” or “Plan”) and compile and submit required Equal Employment Opportunity (“EEO”) and Veterans’ Employment reports.

Collect and analyze employment data and measure the effectiveness of the affirmative action program through this data.

Work with management in identifying problems and provide management with information, and support as needed, in areas relating to affirmative action and the entire equal employment area.

Develop action-oriented programs that establish goals and objectives to identify and remove barriers, if any, to ensure ongoing equal employment opportunity.

Provide for internal and external communication of affirmative action policies, plans and procedures.

Act as a contact person for any staff who has an equal employment opportunity or affirmative action concern.

Observe the work environment for any real or perceived barriers to equal opportunity and recommend corrective action. This includes ensuring that all posters are properly displayed.

Serve as liaison with minority and women’s groups, and with disabled and veteran’s groups, and enforcement agencies.

Perform other duties as necessary to develop and maintain an effective affirmative action program.

PSI AAP 2013 Page 5

PRIOR YEAR’S AAP AND PERFORMANCE Summary of Prior Year’s Affirmative Action Plan – Demonstration of Good-Faith Effort 2009 was the first year that PSI’s payroll grew to over 50 persons and Plan year February 1, 2010 through January 31, 2011 was PSI’s first AAP. Gathering statistics over the last few years has given us the data required to evaluate the composition of PSI’s workforce and compare it to the composition of the relevant external labor pools, and to evaluate the impact of staffing decisions on minorities and women. We have made significant progress in our action-oriented programs this past year, including continuing the process of writing job descriptions, refining our hiring and selection processes, reviewing our compensation structures, revising our employment and benefits manuals, and expanding our recruitment efforts, as follows: 1. Position Descriptions: We evaluated and wrote job descriptions for two new Corporate staff positions in order to accurately describe the essential functions of the job, including education, experience, and skill requirements necessary to qualify for the job. These job descriptions were used for a compensation analysis of these positions. 2. Hiring-Selection: We continued the evaluation of our hiring and selection processes. HR continued to work closely with hiring managers to assist them and maintain consistency in the recruiting, selection and hiring processes.

3. Compensation Systems: For several science support staff positions, we identified job tasks, comparing them to the market and reviewed salaries. We also updated a salary analysis of scientist salaries and prepared a chart of median salaries the scientists may use as a gauge when determining the salary they should submit in their proposals. As we go through this activity, we are also reviewing salary setting procedures to ensure there is no apparent gender, race, or ethnicity-based discriminatory practices. 4. Employee Handbook: We continue the process of revising our personnel and benefits manuals. We anticipate our new employee handbook will be an important communication tool and will set forth our expectations of employees as well as describe what employees can expect from PSI. We were not able to complete the handbook as anticipated by end of January, 2013. Our new completion date goal is 2014.

5. Recruitment Efforts: We continued our recruitment policy to include posting for some jobs on state workforce job boards and with other sites and agencies that may reach minorities, women, veterans and persons with a disability.

6. Availability Factor Analysis: Our AAP for the prior year addressed the availability factor analysis required at the time the Plan was prepared. The analysis compared the incumbent workforce by job group to the external and internal availability of women and minorities. Each of the availability factors required in the regulations was considered. The workforce analysis showed hiring of females in all job categories did not require placement goals. Under-representation of minorities was noted in the Administrative Support job category. In 2012, only one job opening occurred in the Administrative Support job category. That position was advertised on the AZ Workforce Job Board and at the University of Arizona. Only one applicant applied and she was hired.

PSI AAP 2013 Page 6

BRANCH LOCATIONS

PSI’s principal place of business is in Tucson, Arizona. It does not have any branch locations, although PSI employs scientists and has appointee scientists all over the U.S. Scientists outside Tucson work from their home or other locations that are not PSI sites.

PSI AAP 2013 Page 7

INTRODUCTION TO AAP

PSI seeks to establish a creative and productive environment for doing excellent research in planetary science, astronomy, astrophysics and related sciences. PSI is an Institute run by scientists for the benefit of science and science education. As such, we subscribe to the following commitments:

We encourage new ideas, high quality research and professional achievement.

We treat our fellow staff members with respect and honesty and shall ensure equal opportunity for employment and advancement.

We share rewards of success with all whose honest efforts contribute to that success. This AAP reflects the commitment of PSI to ensure equal opportunity for all of its applicants and staff and to correct any barriers, if any are identified, to equal employment opportunity and advancement. PSI’s current AAP covers the 12-month period of February 1, 2013 to January 31, 2014.

PSI AAP 2013 Page 8

ORGANIZATION DISPLAY AS OF 1/31/2013

A = Asian

B = Black or African American

F = Female

H = Hispanic or Latino

I = American Indian or Alaska Native

M = Male

N = Native Hawaiian or Other Pacific Islander

T = Two or more races

W = White

CEO and Director

1WM

Scientists

2AF, 32WF, 1TF

4AM, 1HM, 46WM

Corporate Management

4WF, 4WM, 1TM

Science Support Staff and Computer Professionals

6WF, 2AM, 7WM

Corporate Support Staff

4WF, 1WM

PSI AAP 2013 Page 9

JOB GROUP ANALYSIS

In order to establish each job group, PSI has surveyed its workforce and placed various positions into groups having similar content, wage rates, and opportunities. The Job Group Analysis is a listing of all the job titles that make up each job grouping. The sex and race of each incumbent in the various jobs are also identified. See below for the listing of job titles that comprise each subgroup. Different salary ranges have been combined within job groupings in order to make each grouping large enough to be statistically significant. This is in response to the regulations’ emphasis on grouping jobs with similar responsibility, similar pay or salary clusters, and similar opportunities for training, transfer, and advancement. Officers and Managers (10 staff) (“Managers”) Chief Executive Officer and Director Chief Advancement Officer and Deputy Director Chief Financial Officer Controller IT Manager Human Resources Specialist Public Information Officer Development Officer Sponsored Projects Manager Office Manager Scientists (86 staff) (“Scientists”) Senior Scientist Research Scientist Associate Research Scientist Education Specialist Postdoctoral Research Scientist Science, Engineering and Computer Professionals (15 staff) (“Professionals”) Research Associate Education Support Specialist Software Developer Research Assistant IT Technician Infrastructure System Administrator Administrative Support (5 staff) (“Admin”) Accountant Asst Admin/Newsletter Editor Student ___________________________________________________________________________

Total 116 staff

PSI AAP 2013 Page 10

JOB GROUP ANALYSIS

MALE

FE-

MALE

EEO

Job Group

AI/

AN

Asi

an

Bla

ck/

AA

His

pan

ic/

Lati

no

NH

/ O

PI

Wh

ite

Two

or

mo

re

race

s

Total

AI/

AN

Asi

an

Bla

ck/

AA

His

pan

ic/

Lati

no

NH

/ O

PI

Wh

ite

Two

or

mo

re

race

s

Total Grand Total

1 & 2 Managers 0 0 0 0 0 5 1 6 0 0 0 0 0 4 0 4 10

3 Scientists 0 4 0 1 0 46 0 51 0 2 0 0 0 32 1 35 86

3 Professio

nals 0 2 0 0 0 7 0 9 0 0 0 0 0 6 0 6 15

6 Admin 0 0 0 0 0 1 0 1 0 0 0 0 0 4 0 4 5

TOTAL 0 6 0 1 0 59 1 67 0 2 0 0 0 46 1 49 116

American Indian or A person having origins in any of the original peoples of North and South America (including Central America), Alaska Native and who maintains tribal affiliation or community attachment. Asian A person having origins in any of the original peoples of Far East, Southeast Asia, or the Indian subcontinent

including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand and Vietnam.

Black or African American A person having origins in any of the black racial groups of Africa. Hispanic or Latino A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture or origin, regardless of race. Native Hawaiian or A person having origins in any of the original peoples of Hawaii, Other Pacific Islander Guam, Samoa, or other Pacific Islands. White A person having origins in any of the original peoples of Europe, the Middle East, or North America, who is not of Hispanic origin. Two or More Races A person of two or more races.

PSI AAP 2013 Page 11

JOB GROUP ANALYSIS – PERCENTAGE WOMEN AND MINORITIES Job Groups Female % Female Male % Male Minority % Minority Non-

Minority % Non-

Minority Grand Total

Managers 4 40% 6 60% 1 10% 9 90% 10

Scientists 35 40% 51 60% 8 9% 80 91% 86

Professionals 6 46% 9 54% 2 15% 11 85% 15

Admin 4 80% 1 20% 0 0 5 100% 5

Grand Total 49 42% 67 58% 11 9% 105 91% 116

PSI AAP 2013 Page 12

DETERMINATION OF AVAILABILITY AND COMPARISONS OF INCUMBENCY TO AVAILABILITY

Availability Factor Computation Job Group: Managers

Minorities Female

Factor Factor

Description Incumbents

% of Minorities

in Job Group

Avail. %

Final Weighted

Availability %

Incumbents

% of Females

in Job Group

Avail. %

Final Weighted

Availability %

Source and Reason for Statistics

1

External Avail. For

Reasonable Recruitment

Area

1

10% 27.3% 27.3%

4

40% 42.7% 42.7%

2010 EEO Census Data Tucson MSA

2

Internal Avail.

(Feeder Groups)

0% 0% 0% 0% Feeder Group

Composition

Minorities Female

Factor Avail. % Weight Final

Weighted Availability %

Avail. % Weight Final

Weighted Availability %

Source and Reason for Weighing Factors

1 27.3% 100% 27.3% 42.7%

100%

42.7% Hires

Externally

2 0% 0% 0% 0% 0% 0% Transfers or Promotions

Total Minority Final Availability 27.3% Total Female Final Availability 42.7%

To determine the % of qualified persons available for each of the job groups, we used 2010 EEO Census Data for the appropriate geographic area (for managers it is Tucson). The feeder group would be anyone currently employed by PSI that would be ready for promotion within the job group. Currently, PSI does not have a structure for promotion from within its organization. Therefore, on this chart and the next three charts, all of the number 2 factors are zero, and the external factor is weighted at 100% of availability.

PSI AAP 2013 Page 13

DETERMINATION OF AVAILABILITY AND COMPARISONS OF INCUMBENCY TO AVAILABILITY (cont’d)

Availability Factor Computation Job Group: Scientists

Minorities Female

Factor Factor

Description Incumbents

% of Minorities

in Job Group

Avail. %

Final Weighted

Availability %

Incumbents

% of Females

in Job Group

Avail. %

Final Weighted

Availability %

Source and Reason for Statistics

1

External Avail. For

Reasonable Recruitment

Area

8

9% 15.4% 15.4%

35

42% 17.9% 17.9%

2010 EEO Census Data

US

2

Internal Avail.

(Feeder Groups)

0% 0% 0% 0% Feeder Group

Composition

Minorities Female

Factor Avail. % Weight Final

Weighted Availability %

Avail. % Weight Final

Weighted Availability %

Source and Reason for Weighing Factors

1 15.4% 100% 15.4% 17.9%

100%

17.9% Hires

Externally

2 0% 0% 0% 0% 0% 0% Transfers or Promotion

Total Minority Final Availability 15.4% Total Female Final Availability 17.9%

PSI AAP 2013 Page 14

DETERMINATION OF AVAILABILITY AND COMPARISONS OF INCUMBENCY TO AVAILABILITY (cont’d)

Availability Factor Computation Job Group: Professionals

Minorities Female

Factor Factor

Description Incumbents

% of Minorities

in Job Group

Avail. %

Final Weighted

Availability %

Incumbents

% of Females

in Job Group

Avail. %

Final Weighted

Availability %

Source and Reason for Statistics

1

External Avail. For

Reasonable Recruitment

Area

2

15% 28.1% 28.1%

6

46% 23.3% 23.3%

2010 EEO Census Data

U.S.

2

Internal Avail.

(Feeder Groups)

0 0% 0% 0% Feeder Group

Composition

Minorities Female

Factor Avail. % Weight

Final Weighted

Availability %

Avail. % Weight

Final Weighted

Availability %

Source and Reason for Weighing Factors

1 28.1% 100% 28.1% 23.3%

100%

23.3% Hires

Externally

2 0% 0% 0% 0% 0% 0% Transfers or Promotions

Total Minority Final Availability 28.1% Total Female Final Availability 23.3%

PSI AAP 2013 Page 15

DETERMINATION OF AVAILABILITY AND COMPARISONS OF INCUMBENCY TO AVAILABILITY (cont’d)

Availability Factor Computation Job Group: Admin

Minorities Female

Factor Factor

Description Incumbents

% of Minorities

in Job Group

Avail. %

Final Weighted

Availability %

Incumbents

% of Females

in Job Group

Avail. %

Final Weighted

Availability %

Source and Reason for Statistics

1

External Avail. For

Reasonable Recruitment

Area

0

0% 43.6% 43.6%

4

80% 72.2% 72.2%

2010 EEO Census Data Tucson MSA

2

Internal Avail.

(Feeder Groups)

0% 0% 0% 0% Feeder Group

Composition

Minorities Female

Factor Avail. % Weight Final

Weighted Availability %

Avail. % Weight Final

Weighted Availability %

Source and Reason for Weighing Factors

1 43.6% 100% 43.6% 72.2%

100%

72.2% Hires

Externally

2 0% 0% 0% 0% 0% 0% Transfers or Promotions

Total Minority Final Availability 43.6% Total Female Final Availability 72.2%

PSI AAP 2013 Page 16

SET PLACEMENT GOALS PSI has established a percentage placement goal equal to availability whenever the current representation of females or minorities is less than 80% of the availability percentage and equal to at least one person. The percentage placement goal is not a quota or target for actual employment. It is a trigger for reviewing hiring and retention practices to ensure that the deviation from the availability percentage to actual is not due to discriminatory practices.

PSI AAP 2013 Page 17

PLACEMENT GOALS

Female Male Under-Utilization Goals*

Job Group Class

Job Group Minority Non-

Minority Total Minority

Non-Minority

Total Grand Total

Minority Total

% Minority

Work- force

Final Weighted

Total Minority

Avail- ability %

Female Total

% Female Work- force

Final Weighted

Female Avail-

ability %

Minority Female Minority Female

1 Managers 0 4 4 1 5 6 10 1 10% 27.3% 4 40% 42.7% Yes No 1 0

2 Scientists 3 32 35 5 46 51 86 8 9% 15.4% 35 42% 17.9% Yes No 2 0

2 Profes- sionals

0 6 6 2 7 9 15 2 15% 28.1% 6 46% 23.3% Yes No 0 0

5 Admin 0 4 4 0 1 1 5 0 0% 43.6% 4 80% 72.2% Yes No 1 0

Grand Total

3 46 49 8 59 67 116 4 0

*This is the number of people that would have to be added in order to reach the 80% of availability percentage. A number of one or greater is sufficient to trigger an internal review. This does not define a hiring requirement.

PSI AAP 2013 Page 18

ANALYSIS OF AVAILABILITY FACTOR COMPUTATION, PLACEMENT GOALS, AND ACTION-ORIENTED PROGRAMS TO CORRECT DEFICIENCIES

The workforce analysis shows hiring of females in all job categories does not require placement goals. We will continue to strive to make PSI a favorable work environment for women as we have in the past. The following addresses any action-oriented programs related to minorities. Officers and Managers Job Group In the event we have a permanent, benefits eligible job opening within the Plan year, we will recruit on various Tucson job websites and do other appropriate advertising to attract applicants in large minority pools. Scientists For this analysis, we used an average of the availability pool for Astronomers and Physicists and for Atmospheric and Space Scientists in the 2010 Census. The pool, however, may not be truly reflective of scientists from which PSI may employ and may not be a true representation of the labor market. PSI does not recruit scientists, and scientists who apply to PSI must develop their own independent, externally funded research program. Science, Engineering and Computer Professionals Our analysis shows we have met goals with respect to minorities in this job group. Administrative Support Currently we do not employ any minorities in an administrative support position. If a benefits eligible position becomes open within the Plan year, we will recruit on various Tucson job websites and do other appropriate advertising to attract applicants in large minority pools.

PSI AAP 2013 Page 19

STATEMENT REGARDING REASONABLE RECRUITMENT AREA

External Recruitment Area Officers and Managers: Because all of the officers and managers are located in Tucson, Arizona, we determined that the reasonable recruitment area for this job group was the Tucson metropolitan area. This location has a large population of qualified minorities and females. Scientists: PSI welcomes applications from scientists from around the world; however, they either must be U.S. citizens or be authorized to work in the U.S. PSI scientists conduct field work in North America, Australia and Africa. They are also involved in science education and public outreach. We have determined that the reasonable recruitment area is the U.S. PSI has a good relationship with many Universities and professional organizations across the country and has been successful in attracting female professionals. Science, Engineering, and Computer Professionals: PSI hires Research Assistants, Software Developers, and IT professionals where needed across the country. Therefore, we have used the total U.S. as the recruitment area. Universities are generally the recruiting area for scientists looking for people to support their research and PSI has good relationships with Universities with planetary science programs across the country. Administrative Support: We have determined that the reasonable recruitment area for administrative support personnel is the Tucson metro area. There is a large minority and female population in this area from which to attract qualified applicants. Research assistants are students hired by scientists to assist them in their research projects and may be hired locally. The student must have the education, experience and research ability necessary to support the scientist’s program. Internal Recruitment Officers and Managers: Top management and department specific functions are each handled by one person. There is currently no staff in line for promotion to these positions. Scientists: Scientists joining PSI must be able to submit proposals and receive funding from various sources in order to remain in the employ of PSI. Scientists apply to PSI and work on grants for which they receive funding mainly from NASA. Science, Engineering, and Computer Professionals: This group of professionals includes Research Associates, Software Developers, Research Assistants and IT Technicians. These positions are filled externally as support positions are needed depending upon the specific research project and funding. Administrative Support: Administrative positions are generally unique and handled by one person. There are no personnel in line for these positions. Students are hired by scientists needing support for one or more of their grants and are hired locally.

PSI AAP 2013 Page 20

REVIEW OF COMMON POTENTIAL PROBLEM AREAS

An in-depth analysis has been made of job groups to identify areas where potential problems have or might occur. The result of the analysis is as follows: 1. Workforce Composition The composition of the workforce by organizational units and job groups has been determined. The job group analysis, which considered the availability factor analysis specified in 41 CFR 60-2.12 and the corrective action by the establishment of goals, is located elsewhere.

Women represent 42% of the workforce of PSI.

Minorities represent 9% of the workforce. Under-representation of minorities was noted in the Manager, Scientist, and Administrative job groups. 2. Applicants/Hires During 2012, 15 individuals were hired by PSI, which included seven women and eight males. None of the hires was a minority. Nine of the positions were scientists, and four were students or science support staff hired to support scientists based on their particular expertise. Two hires were for top management positions. All hiring managers are aware that PSI is an equal opportunity employer. A formalized recruiting process for appropriate, non-scientist positions is in place at PSI and continues to be communicated to all hiring personnel. 3. Selection Process PSI welcomes applications from scientists interested in joining PSI’s research community. Candidates are expected to develop their own independent, externally funded research program. Completed applications are reviewed and discussed by the PSI science staff. A review of the qualifications required and the final selection process have been conducted and found not to have unnecessary qualification requirements tending to discriminate against minorities and females. PSI has been and continues to be an equal opportunity employer. The total selection process of staff positions and hire rates for females and minorities were compared to actual hire rates and no problems were indicated in the selection process. Because PSI continues to grow in size, we are continually in the process of reviewing and revising formal job descriptions for all management and support positions, and refining written documentation including application forms, interview procedures, and recruitment procedures. As new and revised processes and procedures are instituted, they will be communicated to appropriate staff with hiring responsibilities.

PSI AAP 2013 Page 21

REVIEW OF COMMON POTENTIAL PROBLEM AREAS (cont’d)

4. Promotions/Transfers

An analysis of promotions and transfers in all job groups has been conducted. Promotions for scientists are based on the number of years of experience beyond Ph.D. In a few cases of highly experienced scientists without a Ph.D., equivalent relevant experience may substitute for a degree. Other than promotions based on years beyond Ph.D., there were no promotions in 2012.

In 2012, we continued to review the job tasks and salaries of Corporate Staff. This Plan year, we plan to continue that review process with a goal of formalizing a compensation structure which may include implementing a process for promotion or progression for appropriate management, staff and scientist support positions.

5. Terminations

The analysis of voluntary terminations by job group, race, and sex indicated that appropriate procedures are followed. The involuntary termination procedures of PSI are consistently applied regardless of the race or gender of the employee. Based on review of individual terminations, the termination procedures of PSI are not considered to be a problem area.

Our records indicate that eight separations took place in 2012, which included four women and two minorities. All of the terminations were voluntary. One scientist had been inactive for a number of years and had taken on a new job. Two scientists had not received any funding for a number of years and decided to seek other opportunities. One scientist moved out of the country because of her husband’s job. One employee had not been on the payroll for a number of years and his status changed to that of a volunteer. The other three terminations were student research assistants (temporary positions) and the projects on which they were working ended or they went back to school.

6. Compensation Systems

PSI currently benchmarks the salary ranges of scientists and those supporting scientists against the salary ranges of similar people in the field. For management and staff positions, salary surveys in the particular geographic region for comparable jobs are reviewed on an as needed basis. During 2012, we updated a salary structure for our scientists based on the average median base salaries for Astronomers and Geologists on a national level. The salary structure includes a recommended minimum salary target for scientists to consider when preparing proposal budgets. We also performed a compensation review of some of the science support staff, including software developers.

7. Other Potential Problem Areas

We have examined other potential problem areas such as facilities, social events, seniority practices, and general workforce attitude, and have determined that no problems exist.

PSI AAP 2013 Page 22

NEW HIRES 2012

JOB GROUP FEMALE MALE GRAND TOTAL

Minority Nonminority Total Minority Nonminority Total

Managers 0 0 0 0 2 2 2

Scientists 0 5 5 0 4 4 9

Professionals 0 1 1 0 2 2 3

Admin 0 1 1 0 0 0 1

GRAND TOTAL 0 7 7 0 8 8 15

2012 Hiring Analysis: Managers: Two top level management positions were created and filled in 2012.

Deputy Director and Chief Advancement Officer: One of the members of PSI’s Board of Trustees was specifically recruited for this position. PSI required a person with his experience and background to lead the Institute’s advancement activities and to serve as the Deputy Director.

Controller: The incumbent was recruited for this position because of his previous experience with PSI’s tax/accounting firm and he had headed several financial audits of the Institution.

Scientists: PSI received nine applications for scientist positions, and all nine were hired. Professionals: Of the three hires:

One was a graduate student employed as a part-time Research Assistant. We recruited for this position through the AZ Workforce Job Board. We hired the only applicant. The other two hires were Senior Research Associates who were already working for a Principal Investigator who was hired with funding for a specific research project.

Admin: With respect to the Administrative category, a college student was hired in a part-time position as a Research Assistant. We recruited for this position through the AZ Workforce Job Board and the job board at the University of Arizona. We hired the only applicant.

PSI AAP 2013 Page 23

NEW HIRES 2012 – MINORITY COMPARED WITH NONMINORITY

JOB GROUP MINORITY NONMINORITY TOTAL APPLICANTS

TOTAL NEW HIRES

Applicants* New Hires Applicants* New Hires

Managers** 0 0 2 2 2 2

Scientists 0 0 9 9 9 9

Professionals 0 0 3 3 3 3

Admin 0 0 1 1 1 1

GRAND TOTAL 0 0 15 15 15 15

* An application is considered commenced when there is an open position and PSI receives a required, completed element for applying to that position. Only applications with all required elements completed will be considered for that position. ** The two manager positions were not recruited. The two hires were based on known individuals who had the expertise and knowledge needed for the required positions.

PSI AAP 2013 Page 24

NEW HIRES 2012 – MALE COMPARED WITH FEMALE

JOB GROUP MALE FEMALE TOTAL APPLICANTS

TOTAL NEW HIRES

Applicants* New Hires Applicants* New Hires

Managers** 2 2 0 0 2 2

Scientists 5 5 4 4 9 9

Professionals 1 1 2 2 3 3

Admin 0 0 1 1 1 1

GRAND TOTAL 8 8 7 7 15 15

* An application is considered commenced when there is an open position and PSI receives a required, completed element for applying to that position. Only applications with all required elements completed will be considered for that position. ** The two manager positions were not recruited. The two hires were based on known individuals who had the expertise and knowledge needed for the required positions.

PSI AAP 2013 Page 25

COMPLIANCE WITH EQUAL PAY ACT AND COMPENSATION SYSTEMS ANALYSIS

We have analyzed our workforce, comparing the salary ranges of similar job titles and job groups, and found that we are in total compliance with the Equal Pay Act of 1963. We have determined that there is no statistically significant difference within common cohorts in the average salaries for women and minorities at PSI. Scientists set their own salaries, informed by company guidelines based on national statistics of similar people in the field. We plan to update our salary guidelines for scientists each Plan year.

PSI AAP 2013 Page 26

COMPENSATION SYSTEMS ANALYSIS – GENDER

JOB GROUP DATA FEMALE MALE TOTAL Number of Staff 4 6 10

Average Salary $66,383 $115,107 $95,618

MANAGERS Salary Differential* 69% 120% 100%

Years Beyond PhD 26

Number of Staff 35 51 86

Average Salary $94,713 $102,051 $99,065

SCIENTISTS Years Beyond PhD 13 18 16

Salary Differential* 96% 103% 100%

Years Beyond PhD* 81% 113% 100%

Number of Staff 6 9 15

Average Salary $57,645 $91,285 $77,829

PROFESSIONALS Salary Differential* 74% 117% 100%

Years Beyond PhD 25

Number of Staff 4 1 5

ADMIN Average Salary $32,131 $24,960 $30,697

SUPPORT Salary Differential* 105% 81% 100%

Number of Staff 49 67 116

Average Salary $82,753 $100,623 $93,075

TOTALS Years Beyond PhD 10 15 12

Salary Differential* 89% 108% 100%

Years Beyond PhD* 83% 125% 100%

*from total Under the Manager Group, only the Director has a Ph.D. Under the Professional Group, one Senior Research Associate has a Ph.D.

PSI AAP 2013 Page 27

COMPENSATION SYSTEMS ANALYSIS – MINORITY

JOB GROUP DATA MINORITY NON-MINORITY TOTAL Number of Staff 1 9 10

Average Salary $95,181 $95,666 $95,618

MANAGERS Salary Differential* 100% 100% 100%

Years Beyond PhD 26

Number of Staff 8 78 86

Average Salary $91,199 $99,871 $99,065

SCIENTISTS Years Beyond PhD 13 16 15

Salary Differential* 92% 101% 100%

Years Beyond PhD* 87% 107% 100%

Number of Staff 2 13 15

Average Salary $43,680 $83,083 $77,829

PROFESSIONALS Salary Differential* 56% 107% 100%

Years Beyond PhD 25

Number of Staff 0 5 5

Average Salary $30,697 $30,697

ADMIN Salary Differential* 100% 100%

SUPPORT

Number of Staff 11 105 116

Average Salary $82,921 $92,969 $92,016

TOTALS Years Beyond PhD 10 13 12

Salary Differential* 90% 101% 100%

Years Beyond PhD* 83% 108% 100%

*from total Under the Manager Group, only the Director has a Ph.D. Under the Professional Group, one Senior Research Associate has a Ph.D.

PSI AAP 2013 Page 28

DEVELOPMENT AND EXECUTION OF ACTION-ORIENTED PROGRAMS

PSI has grown over the last year and we foresee continued growth. At a minimum, PSI will be developing the following action-oriented programs during this Plan year: 1. Position Descriptions We will continue the process of writing job descriptions for all positions within PSI. Those descriptions will accurately reflect the position functions and will be consistent for the same position from one location to another. Further, the job descriptions will include the essential functions of the job, including education, experience, and skill requirements necessary to qualify for the job. In addition, for those positions where job descriptions have been written, we will continue to analyze and update them appropriately as the duties of the position change. The job descriptions will be distributed to members of management, recruitment personnel and referral sources as appropriate. 2. Hiring-Selection We will continue to periodically evaluate our selection process to ensure freedom from bias. Personnel involved in the recruiting, screening, selection, promotion, discipline and related processes will be trained appropriately. We will make a good faith effort to remove any identified barriers, expand employment opportunities, and produce measurable results. 3. Compensation Systems We will continue to review our compensation systems periodically to ensure there is no apparent gender, race, or ethnicity-based discriminatory practices and take corrective action if necessary. We have a compensation program directed toward attracting, retaining and rewarding a qualified and diverse workforce, within the boundaries of financial feasibility. 4. Employee Handbook We are well underway in revising our personnel and benefits manuals. We anticipate our new employee handbook will be an important communication tool and will set forth our expectations of employees as well as describe what employees can expect from PSI. 5. Recruitment Efforts PSI does not formally recruit for scientists within the planetary science community. All scientists in the field are welcome to apply at any time. PSI is an Institute that is run by scientists for the benefit of science and science education. As such, PSI contributes to the education and development of future scientists through the opportunities for them to participate in research activities at PSI. With respect to staff positions and scientist support personnel, as openings for benefits eligible positions occur, we will expand our recruitment efforts when appropriate to include job postings at sites or through agencies that may reach minorities, women, veterans, and persons with a disability.

PSI AAP 2013 Page 29

CORPORATE MANAGEMENT COMPLIANCE EVALUATION

In compliance with the directives on “Corporate Management Compliance Evaluations,” PSI has examined its developmental and selection criteria for artificial barriers to advancement into mid-level and senior-level positions (i.e., glass ceiling). No barriers or potential equal employment opportunity barriers were identified. The Corporate Management Review also did not find any unlawful discrimination in the selection processes and practices for mid-level and senior-level management positions. Minorities, women, individuals with a disability, and covered veterans already in those positions are treated in a nondiscriminatory manner in all aspects of their employment.

PSI AAP 2013 Page 30

EQUAL EMPLOYMENT POLICY

Federal and state laws prohibit employment discrimination. It is the policy of the Planetary Science Institute (PSI), when recruiting, hiring, training, promoting, and terminating staff to make a good faith effort to comply with those laws that prohibit discrimination as to race, color, religious creed, age, national origin, ancestry, sex, sexual orientation, gender identity, pregnancy, marital status, or mental or physical disability, unless it is shown that such disability prevents performance of the work involved. As CEO and Director, I reaffirm that the above policy and the Affirmative Action Plan executed simultaneously herewith, reflect PSI’s attitude and its intention to: 1. Recruit, hire, train, and promote for all job classifications without regard to race, color, religious creed, age, national origin, ancestry, sex, sexual orientation, gender identity, pregnancy, marital status, or mental or physical disability, unless it is shown that such disability prevents performance of the work involved. 2. Base decisions on employment so as to further the principles of equal employment opportunity. 3. Ensure that promotion decisions are in accord with the principles of equal employment opportunity. 4. Ensure that all other personnel actions, such as compensation, benefits, and terminations will be administered without regard to race, color, religious creed, age, national origin, ancestry, sex, sexual orientation, gender identity, pregnancy, marital status, or disability. 5. Provide, pursuant to the Rehabilitation Act of 1973, as amended, equal employment opportunities to qualified persons with a disability. 6. Provide, pursuant to the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended, equal opportunities to those who are covered veterans. PSI in compliance with Executive Order 11246, as amended, the Rehabilitation Act of 1973, as amended, and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended, maintains written Affirmative Action Plans. These Plans are available for inspection upon request to Linda Rueger, PSI’s HR Specialist and Equal Employment Opportunity Administrator, during business hours. This policy has the full backing and support of the management of PSI. The support of all staff is expected as well.

Mark V. Sykes, Ph.D., J.D. CEO and Director February 1, 2010

PSI AAP 2013 Page 31

ANTI-SEXUAL HARASSMENT POLICY

PSI is committed in all areas to providing a work environment that is free from sexual harassment. In 1980, the Equal Employment Opportunity Commission (EEOC) first published guidelines on sexual harassment, and this policy is to emphasize how strongly PSI management feels about the importance of a productive work environment that is free of harassment. All staff, including supervisors and other management personnel, are expected and required to abide by this policy.

Sexual harassment is behavior of a sexual nature that is unwelcome and offensive to the person or persons it is targeted toward. Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute harassment when (1) submission to or rejection of such conduct is made either explicitly or implicitly a term or condition of an individual's employment; (2) submission to or rejection of such conduct by an individual is used as the basis for decisions about employment, promotion, selection for training, performance evaluations, benefits, or other terms and conditions of employment; or (3) such conduct has the purpose or effect of creating an intimidating, hostile, or offensive work environment or substantially interferes with an employee's work performance.

Examples of harassing behavior may include unwanted physical contact, foul language of an offensive sexual nature, sexual propositions, sexual jokes or remarks, obscene gestures, and displays of pornographic or sexually explicit pictures, drawings, or caricatures. Use of PSI's computer system for the purpose of viewing, displaying, or disseminating material that is sexual in nature may also constitute harassing behavior. Any employee who feels that he or she is the victim of a workplace incident of sexual harassment is encouraged to discuss the matter promptly with Mark Sykes, CEO and Director, or Linda Rueger, HR Specialist and EEO Administrator. Once the matter has been reported, it will be promptly investigated and any necessary corrective action will be taken where appropriate. No form of reprisal will be applied to any person making a complaint of sexual harassment. PSI supports the spirit and objectives of the Equal Employment Opportunity Commission (EEOC) guidelines on sexual harassment. It is our policy that anyone in our organization who is found to have engaged in such harassment of another employee will be subject to disciplinary action, up to and including termination. We expect that our staff will act in a responsible and professional manner, remain sensitive to treating their co-workers with dignity and respect, and help us to provide a productive work environment.

Mark V. Sykes, Ph.D., J.D. CEO and Director February 1, 2010

PSI AAP 2013 Page 32

COMPLIANCE WITH SEX DISCRIMINATION GUIDELINES

In order to comply with the federal Sex Discrimination Guidelines (Executive Order 11246), we follow the following procedures and practices: 1. Candidates are recruited without regard to sex. 2. Advertisements include the information that we are an equal employment opportunity employer. 3. Written personnel policies include language indicating that there is no discrimination on the basis of a person’s sex. 4. Staff members and applicants of both sexes have equal opportunities for available jobs for which they are qualified to perform. 5. No distinctions are made based on a person’s sex in employment opportunities, wages, hours of work, staff benefits, or any other condition of employment. 6. Appropriate facilities are provided for both sexes. 7. Promotions are not based on a person’s sex. 8. Salaries are not based on a person’s sex. 9. Our anti-sexual harassment policy is communicated to staff and is strictly enforced. 10. We make no distinctions between married or unmarried persons in any of our hiring or other personnel policies. 11. We do not exclude either sex from any job. 12. Women have equal opportunities to participate in training programs.

PSI AAP 2013 Page 33

DISSEMINATION OF AFFIRMATIVE ACTION POLICY

PSI has established various channels of communication to ensure that staff and the community are aware of PSI’s positive posture toward equal employment opportunity (EEO) and affirmative action. Internal Dissemination

The affirmative action policy is stated as part of PSI’s equal employment opportunity policy.

PSI’s AAP is developed with the assistance of key managers and staff members.

In management and supervisory training, the entire concept of affirmative action is covered, as well as our policy and implementation.

When we hire, new staff will be formally made aware of our policy on affirmative action and anti-harassment, sex discrimination guidelines, and the Equal Pay Act. These policies are posted at a number of locations both at the facility and we are working on posting them on our internal website pages.

Key management and appropriate support personnel will undergo EEO and affirmative action training from time to time. Supervisors and managers will participate in the review of underutilized categories and in the setting of affirmative action goals.

Our affirmative action program will be monitored on a quarterly basis. External Dissemination

As part of our policy of good communications, we will notify appropriate recruiting sources with whom we work of PSI’s policy concerning EEO and affirmative action. When hiring occurs, we will request referral of qualified women and minorities for all positions.

Our customers, contractors, and various community groups will be notified of our policies through our website and other advertising.

Written notification of EEO policy, as well as requests for certification regarding compliance with EEO laws, is sent to suppliers and subcontractors.

All “Help Wanted” advertisements carry the notice “Equal Opportunity Employer M/F/Vet/Disab,” and this designation (or one like it) is included in any recruiting brochures and recruiting literature.

PSI AAP 2013 Page 34

RECRUITMENT LETTER

When recruiting personnel through a recruitment agency, the following letter will be sent: Dear [name]: In view of our present association with your agency to recruit for the position of ______________, I would like to take this opportunity to make you aware of the Planetary Science Institute’s (“PSI’s”) policy with respect to recruiting. It has been the policy of PSI to offer all applicants for employment equal opportunity based on qualifications without regard to race, color, religious creed, age, national origin, ancestry, sex, sexual orientation, gender identity, pregnancy, marital status, or disability. In accordance with this policy, you are encouraged to seek out qualified minorities, females, persons with a disability, and covered veteran candidates for consideration with respect to all job opportunities placed with you now or in the future. Thank you for your cooperation. Very truly yours, Linda Rueger HR Specialist Equal Employment Opportunity Coordinator

PSI AAP 2013 Page 35

RECORD RETENTION REQUIREMENTS

In accordance with 41 CFR 60-1.12, we have established the requirement that any personnel or employment record made or kept by us will be retained for a period of not less than one year from the date the record is made or the personnel action is taken. These records include, but are not limited to: records pertaining to applicants, hiring, assignment, promotion, demotion, transfer, termination, rates of pay or other terms of compensation, selection for training, requests for reasonable accommodation, requests for Family Medical Leave, and job advertisements and postings. However, we also acknowledge that there are other federal and state laws that may require us to retain personnel or employment records for a longer period of time. We have developed the following Record Retention Policy to ensure that our personnel records are uniform and in compliance with all relevant regulations. RETENTION PERIODS FOR EMPLOYMENT RELATED RECORDS:

Personnel Files: 7 years from the date of termination.

Health Insurance/Benefits Files (including COBRA notices, plan docs, ERISA-related docs): 6 years

from the date of record or date of filing

FMLA and Requests for Reasonable Accommodation (ADA and FMLA): 3 years from making the

record or taking the action, whichever occurs later, or 3 years after termination

I-9 Forms: 3 years after date of hire or 1 year after date of termination, whichever is later

Employee Exposure and Medical Records (including Worker’s Comp): 30 years after date of

injury/illness

Applications of Persons Not Selected for Position, Job Advertisements and Postings: 3 years from date

of action

Affirmative Action Plans and backup documentation: current and 2 years prior

EEO-1 and VETS 100 Reports: current and 2 years prior

Payroll Records (includes employment tax records): 5 years after termination

If PSI is involved in an employment-related dispute with a terminated employee, until the dispute has been reconciled, all documents pertaining to the employee (and the charge or lawsuit) must be retained.

PSI AAP 2013 Page 36

DEFINITION OF APPLICANT

PSI welcomes applications from scientists interested in joining PSI through the PSI website, referral, and word of mouth. There are required elements for application which are posted on the PSI website, which includes a cover letter, current curriculum vitae, 1-2 page statement of research interests, goals and plans, and a minimum of three references. These documents may be submitted electronically, or in hard copy. For scientist support positions, staff and management, all applicants must complete PSI’s application form to be considered an applicant for employment. If an application is not completed, then we do not define the inquiry as a job application. PSI does not accept unsolicited resumes for these positions. We ask all applicants to voluntarily supply information concerning their race, gender, and ethnicity. This information is maintained in a separate file from the application forms. If applicants do not self-identify, we do our best to make an accurate visual observation and note it on the application form, so that we can use this data for our reporting requirements. Special disabled veterans and other disabled individuals are asked to self-identify after the job offer is made and before the applicant begins work. PSI does accept resumes and applications via electronic means. An application is considered commenced when there is an open position and PSI receives a required, completed element for applying to that position. Only applications with all required elements completed will be considered for that position. PSI maintains the following applicant flow log:

DATE NAME RACE SEX APPLICATION SOURCE

EEO CATEGORY

POSITION APPLIED FOR

DISPOSITION

PSI AAP 2013 Page 37

GLOSSARY OF TERMS

Affirmative Action Those results-oriented actions that PSI must take to ensure equal employment opportunity.

Affirmative Action Plan (AAP)

The written plan incorporating a set of specific and results-oriented procedures to which PSI, as a government contractor, commits itself to apply every good-faith effort to achieve to eliminate discrimination or under-utilization, if any, of minorities and women.

Applicant A person seeking work at PSI as specified in its policy definition of an employment applicant.

Applicant Flow The number of applicants applying for a particular job over a given period of time, analyzed by protected class characteristics.

Appointee Scientist A scientist who has submitted the required documentation and been accepted to write proposal through PSI.

Compliance The degree to which federal contractors or subcontractors carry out the goals and commitments in their affirmative action plans or the nondiscrimination clauses in their contracts.

Discrimination Illegal treatment of a person or a group based on race, sex, disability, or other prohibited factor.

Equal Employment Opportunity

A system of employment practices under which no individuals are excluded from consideration, participation, promotion, or benefits because of their race, color, religion, sex, national origin, age, disability, or veteran status.

Incumbency The percentage of minorities and the percentage of women PSI employs in each job group.

Invitation to Self-Identify An invitation by PSI extended to employees and applicants asking the individual to voluntarily identify himself or herself as disabled or as a veteran, or both.

Job Group One or more positions having similar content, wage rates, and opportunities.

Percentage Placement Goal

When a contractor is required to establish a percentage placement goal for a particular job group, it must establish an annual percentage placement goal at least equal to the availability figure derived for women or minorities, as appropriate, for that job group. Placement goals may not be rigid and inflexible quotas which must be met, nor are they to be considered as either a ceiling or a floor for the employment of particular groups. It is a trigger for reviewing hiring and retention practices to ensure that the deviation from the availability percentage to actual is not due to discriminatory practices.

Reasonable Recruitment Area

The geographical area from which PSI usually seeks or reasonably could see workers to fill certain open positions.

Reasonable Recruitment Area Statement

A required short statement that PSI prepared explaining the rational for the selection of a recruitment area.

Staff For purposes of the AAP, PSI defines staff to include all persons on payroll and appointee scientists not on payroll.

Underrepresentation Fewer minorities or women in a job group than their proportion in PSI’s workforce.

Underutilization Having fewer women or minorities in PSI’s workforce than could reasonably be expected based on their availability in the labor area.

Workforce The total number of staff at PSI.