I. Policy Statement

Family Promise of Puget Sound (FPOPS) is committed to fair, equitable, and non-discriminatory compensation practices, in full compliance with the Washington Equal Pay and Opportunities Act (WEPA). This commitment includes protecting the right of every employee to openly and freely discuss their wages, compensation, and other terms of employment with coworkers or third parties without fear of adverse action.

II. Purpose

The purpose of this policy is to clearly communicate employee rights regarding wage discussions and to affirm FPOPS’s prohibition against retaliation for the exercise of these rights, thereby promoting transparency and pay equity within the organization.

III. Scope

This policy applies to all paid FPOPS employees, including full-time, part-time, and temporary staff, and to all managers, supervisors, and agents of FPOPS.

IV. Guiding Principles

Non-Retaliation: No employee will be disciplined, discharged, demoted, or otherwise penalized for inquiring about, disclosing, comparing, or discussing their wages or the wages of other employees.

Confidentiality: This policy does not require employees to disclose their wages. Employees may choose whether or not to engage in wage discussions.

Privacy: FPOPS management has a corresponding right to maintain the confidentiality of employee and organizational data, provided that doing so does not infringe upon an employee’s right to discuss wages.

V. Definitions

Wages: Includes salary, hourly pay, benefits, bonuses, commission, and all other forms of compensation paid to an employee for services rendered.

Adverse Action: Any form of negative employment action, including but not limited to, demotion, reduction in hours, negative performance review, withholding of promotion, or termination.

Compensation Discussion: Any communication with coworkers, former coworkers, or third parties (such as a union representative or attorney) regarding wages, benefits, or other terms of employment.

VI. Policy Guidelines

A. Employee Rights to Discuss Compensation

FPOPS employees have the guaranteed right to:

Inquire: Ask about their own wages or the wages of any other FPOPS employee.

Disclose: Share their own wage or compensation information with others.

Compare: Discuss differences in compensation between employees.

Discuss: Engage in conversations with coworkers or third parties about wages, hours, and working conditions.

This right extends to discussing compensation details regardless of whether the information was voluntarily disclosed by a coworker or obtained through public means.

B. Prohibited Employer Conduct and Retaliation

FPOPS supervisors and managers are strictly prohibited from engaging in any action that would interfere with an employee’s right to discuss compensation. Prohibited adverse actions include:

Discipline or Termination: Taking any disciplinary action against an employee (up to and including termination) solely because they inquired about or discussed compensation.

Imposing a Policy of Secrecy: Implementing or enforcing a policy that prohibits, restricts, or otherwise attempts to penalize employees for discussing their wages.

Surveillance: Monitoring or otherwise attempting to discover which employees are discussing wages for the purpose of taking adverse action.

C. Policy on Manager Wage Confidentiality

While managers and supervisors are strictly prohibited from taking adverse action against employees for discussing wages, they must maintain the confidentiality of other employees’ wage information that they possess due to their official duties (e.g., payroll data access). Managers may not proactively disclose the wages of one employee to another.

VII. Responsibilities

Employees: Are encouraged to use their right to discuss wages responsibly and respectfully.

Supervisors/Managers: Must ensure they never discourage, prohibit, or penalize employees for engaging in wage discussions. They are responsible for communicating this policy clearly.

CEO/HR: Is responsible for training supervisors on the non-retaliation provisions of WEPA and ensuring all compensation decisions align with the organization’s pay equity goals.

VIII. Complaint Procedure and External Resources

Employees who believe their right to discuss wages has been violated or that they have been subjected to retaliation must:

Internal Contact (Primary): Immediately report the concern to the CEO or Human Resources. Reports will be investigated under the FPOPS Non-Retaliation and Complaint procedures.

External Contact: The Washington State Department of Labor & Industries (L&I) is the primary governmental agency responsible for enforcing the Washington Equal Pay and Opportunities Act (WEPA).

IX. Policy Review and Revision

This policy will be reviewed by the CEO and/or HR as needed to ensure continued compliance with the Washington Equal Pay and Opportunities Act and may be revised at the discretion of FPOPS.